Case Digest (G.R. No. L-19254)
Facts:
On December 5, 1960, Benguet Consolidated, Inc. (the petitioner) filed a petition with the Social Security Commission regarding its employee, Lamberto Forosan, who sustained an injury while working on September 3, 1960. As a result of this injury, Forosan was unable to work from September 3 to October 8, 1960. The petitioner paid Forosan disability benefits in accordance with Section 14 of the Workmen's Compensation Act. However, on October 12, 1960, the Social Security System (the respondent), through its regional representative in Baguio City, requested the petitioner to pay Forosan sickness benefits under the Social Security Act for the same period during which he had already received workmen's compensation benefits. The petitioner contended that the Workmen's Compensation Act explicitly states that the rights and remedies granted to an employee for personal injury exclude all other rights and remedies against the employer, thus rendering the respondent's d...
Case Digest (G.R. No. L-19254)
Facts:
- Injury and Disability: On September 3, 1960, Lamberto Forosan, an employee of Benguet Consolidated, Inc., suffered an injury while on duty. This injury rendered him unable to work from September 3 to October 8, 1960.
- Payment of Disability Benefits: Benguet Consolidated, Inc. paid Forosan disability benefits under Section 14 of the Workmen's Compensation Act for the period of his injury and disability.
- Demand for Sickness Benefits: On October 12, 1960, the Social Security System (SSS), through its regional representative, demanded that Benguet Consolidated, Inc. pay Forosan social security sickness benefits for the same period.
- Petition to Countermand Demand: Benguet Consolidated, Inc. filed a petition with the Social Security Commission on December 5, 1960, arguing that the demand for sickness benefits was invalid. The company contended that Section 5 of the Workmen's Compensation Act excludes other remedies or benefits for the same injury.
- Respondent's Defense: The SSS argued that the Social Security Act (Republic Act No. 1161, as amended) is a later legislation and its benefits are not precluded by the Workmen's Compensation Act. The SSS also emphasized that social security benefits are distinct and complementary to workmen's compensation benefits.
- Social Security Commission's Decision: On September 11, 1961, the Commission dismissed Benguet's petition and ordered the company to pay Forosan the sickness benefits under the Social Security Act. Benguet's motion for reconsideration was denied on October 26, 1961, prompting the appeal.
Issue:
The primary issue is whether an employee can simultaneously recover sickness benefits under the Social Security Act and disability benefits under the Workmen's Compensation Act for the same injury or disability.
Ruling:
The Supreme Court affirmed the resolution of the Social Security Commission, holding that sickness benefits under the Social Security Act may be recovered simultaneously with disability benefits under the Workmen's Compensation Act.
Ratio:
- (Unlock)