Case Digest (G.R. No. L-16696)
Facts:
The case titled Luciano Escosura, et al. vs. San Miguel Brewery, Inc. (G.R. Nos. L-16696 and L-16702) was adjudicated on January 31, 1962, by the Philippine Supreme Court. The petitioners, Luciano Escosura, Pionisio Asis, Primitivo Binalber, Procopio Cipriano, Florencio Hipolito, Cesar Villareal, and Pablo R. Cruz, were employees of San Miguel Brewery, Inc., which is the respondent. As part of their employment, these employees became compulsorily covered under the Social Security System in September 1957. During their tenure, they fell ill at different times and were hospitalized, leading to periods of confinement. Despite receiving sick leave pay—50% of their wages for the first three days of hospitalization and 75% thereafter—these employees filed claims for sickness benefits under the Social Security Act, asserting their right to such benefits notwithstanding their receipt of partial pay.
The Social Security Commission, in its resolution regarding SSC Cases Nos. 33, 37, 38,
Case Digest (G.R. No. L-16696)
Facts:
- Parties Involved:
- Petitioners-Appellees: Luciano Escosura, Dionisio Asis, Primitivo Binalber, Procopio Cipriano, Florencio Hipolito, Cesar Villareal, and Pablo R. Cruz (employees of San Miguel Brewery, Inc.).
- Respondent-Appellant: San Miguel Brewery, Inc.
- Employment and Coverage:
- Petitioners were employees of San Miguel Brewery, Inc., and became compulsorily covered under the Social Security System (SSS) in September 1957.
- Sickness and Sick Leave Pay:
- During their employment, petitioners fell ill and were hospitalized.
- San Miguel Brewery provided sick leave pay under its Health, Welfare, and Retirement Plan:
- 50% of wages for the first 3 days of confinement.
- 75% of wages thereafter.
- Claims for Sickness Benefit Allowance:
- Despite receiving sick leave pay, petitioners claimed sickness benefit allowances under the Social Security Act (Republic Act 1161) for the duration of their confinement.
- The amounts claimed and periods of confinement were as follows:
- Luciano Escosura: 187 days (Nov. 27, 1958 – June 1, 1959).
- Dionisio Asis: 23 days (March 20, 1959 – April 12, 1959).
- Primitivo Binalber: 29 days (Feb. 2, 1959 – March 2, 1959).
- Procopio Cipriano: 43 days (Nov. 16, 1958 – Dec. 28, 1958).
- Florencio Hipolito: 39 days (Jan. 1, 1959 – Feb. 8, 1959).
- Cesar Villareal: 10 days (April 3, 1959 – April 12, 1959).
- Pablo R. Cruz: 36 days (Jan. 24, 1959 – March 1, 1959).
- Legal Basis for Claims:
- Petitioners argued that under Section 14(a) of Republic Act 1161, receiving sick leave pay less than full wages did not preclude them from claiming sickness benefits under the Social Security Act.
- Employer’s Defense:
- San Miguel Brewery contended that employees who received sick leave pay (even if not full pay) could not claim additional benefits under the Social Security Act, as these benefits were exclusive to employees not receiving any leave privileges from their employer.
- Social Security Commission’s Ruling:
- The Commission ruled in favor of the employees, interpreting the phrase "leaves of absence with pay" in Section 14(a) to mean "full pay."
- The Commission ordered San Miguel Brewery to advance the sickness allowances and seek reimbursement from the SSS for 70% of the amount paid.
Issues:
- Whether the phrase "leaves of absence with pay" in Section 14(a) of the Social Security Act refers to full pay or partial pay.
- Whether employees who receive partial sick leave pay from their employer are entitled to claim sickness benefits under the Social Security Act.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)