G.R. No. L-25292 - Zamboanga Transportation Company, Incorporated vs. Court of Appeals

The petitioner, Ignacio de los Angeles, filed a compensation claim against the Government Service Insurance System (GSIS) and the Employees’ Compensation Commission (ECC).
The claim involved injuries and disabilities sustained when the petitioner experienced a stroke on May 26, 1975, which led to extended hospitalization and eventual forced retirement from the Philippine Coconut Authority.
The petition was part of several claims that invoked the doctrine established in Corales vs. ECC, which allowed claims accrued during the era of the Workmen’s Compensation Act to be resolved under that more favorable law, even though the New Labor Code was later enacted.

The initial proceedings and record submission occurred as early as July 5, 1978, with the case continuously evolving through submissions by both ECC and GSIS.
On January 15, 1979, the Court remanded the records to the ECC for the computation of benefits, instructing the commission to inform the Court of the implementing action within thirty (30) days.
Subsequent manifestations and motions by ECC and GSIS revealed disagreements over:

The proper computation of benefits.
Which set of legal provisions—those of the former Workmen’s Compensation Act or the New Labor Code—should govern the petitioner’s claim.

Despite respondent motions for reconsideration from both ECC (filed on December 26, 1979) and GSIS (filing dated January 7, 1980), the Court maintained its earlier directive and later clarified its position on the merits.

Pay the petitioner P6,000.00 as compensation benefits.
Reimburse his medical, hospital, and surgical expenses upon presentation of proper receipts.
Pay attorney’s fees amounting to P600.00.
Remit administrative fees of P61.00.

ECC argued that if the petitioner’s cause of action accrued during the full effectivity of the Workmen’s Compensation Act, the claimant should have filed before the statutory deadline.
GSIS contended that the case was out of order for a merit decision due to prior remand and that the petitioner’s benefits, if any, should be computed under the New Labor Code.

Multiple manifestos, orders, and telegraphic notices between the petitioner, ECC, and GSIS.
Detailed submissions regarding the petitioner’s medical records, service record, and discrepancies in the computation of benefits.
A critical exchange concerning the failure of the GSIS to deliver certain payments (e.g., a check of P256.00 for temporary total disability) and the petitioner’s repeated pleas for the expedited release of the due compensation.

The Court’s procedural actions were centered on ensuring proper computation, confirmation of the petitioner’s eligibility for benefits, and timely payment.
Despite delays and inconsistent communications from GSIS and ECC—including issues with unclaimed mail and incomplete requirements—the Court stressed that its original remand did not divest it of jurisdiction over the appeal.
The controversy also involved the interpretation of the applicable law:

Whether the petitioner’s cause of action, which accrued during the period of the Workmen’s Compensation Act, should be computed under the older statute or the subsequently amended New Labor Code.

Whether compensation claims with causes of action accrued during the time when the Workmen’s Compensation Act was in full force should continue to be resolved under the provisions of that Act rather than the New Labor Code.

The issue revolves around the application of the Corales doctrine in determining the more favorable legal regime regarding compensation benefits.

Whether the petitioner is entitled to the full array of benefits computed under the Workmen’s Compensation Act, including:

The statutory compensation amount (P6,000.00).
Reimbursement for medical, hospital, and surgical expenses.
Attorney’s fees.
Whether administrative fees should be deducted or not, particularly in light of GSIS’s position.

Whether the Court retained jurisdiction to decide on the merits after remanding the case for benefit computation and receiving further communications from both ECC and GSIS.

The issue also covers the proper resolution of conflicting manifestations and the acceptance or rejection of computed benefits.

Whether GSIS’s right to seek reimbursement from the petitioner’s employer—after paying the compensation benefits—should be recognized despite the application of the former compensation law.