G.R. No. L-27885 - Franklin Baker Company of the Philippines vs. Workmen's Compensation Commission

Franklin Baker Company of the Philippines (“petitioner”) is involved in a special civil action for certiorari and prohibition with a request for a preliminary injunction.
The case pertains to the Workmen’s Compensation Commission’s decision in R05-WC Case No. 25 related to the claim of Salvador Abrigo, an employee, for work-related disability benefits arising from alleged “psycho-neurosis” and other related symptoms.

Salvador Abrigo, an employee since September 10, 1947, held several positions (meat collector, washing foreman, screening operator, assistant opening foreman, and acting electronic counting machine operator).
Abrigo’s claim for compensation was filed on May 27, 1959, covering multiple periods of disability allegedly traceable to his work, including his assignment as an electronic counting machine operator which required sustained concentration.
Abrigo experienced dizziness, constant headaches, and other symptoms which later culminated in a diagnosis of “psycho-neurosis,” subsequently deemed compensable.

On March 27, 1963, hearing officer Domingo A. Reyes ruled that Abrigo’s illness was work-related and ordered petitioner to pay specific amounts for disability compensation, a fee for the decision, and attorney’s fees.
Petitioner’s petition for review of the decision was denied, but the entire case records were escalated to the Workmen’s Compensation Commission.
On January 27, 1964, the Commission rendered a decision awarding compensation of P358.55 for disability covering February 26, 1957, to July 15, 1957, along with additional payments such as counsel’s fee and fees to the Workmen’s Compensation Fund.
Abrigo’s subsequent motion for reconsideration was filed on March 21, 1964, and later denied by the Commission en banc on April 17, 1964.

On July 28, 1964, petitioner issued checks based on the Commission’s award; however, with respect to the P358.55 due to Abrigo, petitioner deducted P118.75.
The petitioner justified the deduction by claiming that the amount had already been paid under its “Non-Occupational Accident and Sickness Disability Benefit Plan” contained in a pre-existing collective bargaining agreement.
On December 6, 1966, the Commission clarified that such a deduction was improper because the payment under the benefit plan was private and could not offset a liability created by law.

Despite the Commission’s order and repeated requests, petitioner refused to remit the deducted amount of P118.75 to Abrigo.
On July 14, 1967, a writ of execution was issued by the Commission’s chairman to enforce payment of the balance.
Petitioner then filed the instant petition, including a supplemental motion for a writ of preliminary injunction to restrain the execution proceedings, which was granted upon posting a bond.

Whether the deduction of P118.75—previously paid by petitioner to claimant Abrigo under its non-occupational accident and sickness disability benefit plan—from the compensation benefits awarded by the Workmen’s Compensation Commission is proper.

Whether an employer may use payments made under a private benefit plan, established by a collective bargaining agreement, to offset or reduce its legal liability under the Workmen’s Compensation Act.
Whether the signing of a “Satisfaction of Award or Decision” by the claimant can be construed as a waiver of his right to recover the full compensation awarded by law.