Case Digest (G.R. No. L-17362)
Facts:
The case involves Madrigal Shipping Co., Inc. as the petitioner and Monica Melad, Francisca Siccuan, Juana Siccuan, Barbara Tuliao, Placida de la Cruz, the Aparri Pilots' Association, and the Workmen's Compensation Commission as respondents. The events leading to the case began on November 25, 1955, when the S.S. "Cetus," owned and operated by Madrigal Shipping Co., departed from the port of Aparri en route to Manila. After traveling approximately five miles, the ship's officers decided to return to Aparri for rudder repairs. The ship's captain sent a telegram to Jua Siong Kong Ho, Inc., the ship's agent in Aparri, instructing them to notify the pilots that the ship would be returning for repairs. The agent relayed this message to the Aparri Pilots' Association, which subsequently dispatched pilots Primitivo Siccuan and Francisco Ricerra, along with Filoteo Siccuan and Domingo Batta, to assist the ship. They reached the S.S. "Cetus"...
Case Digest (G.R. No. L-17362)
Facts:
- Ownership and Operation of the Ship: The S.S. "Cetus" was owned and operated by Madrigal Shipping Co., Inc.
- Incident Leading to the Tragedy: On November 25, 1955, the ship left Aparri for Manila but had to return to port for rudder repairs after sailing five miles. The captain sent a telegram to the ship's agent, Jua Siong Kong Ho, Inc., instructing them to inform the Aparri Pilots' Association about the need for a pilot to re-enter the port.
- Response of the Pilots' Association: The Aparri Pilots' Association dispatched Primitivo Siccuan (chief pilot) and Francisco Ricerra (district pilot) to assist the ship. They were accompanied by Filoteo Siccuan and Domingo Batta, who operated the boat that took them to the ship.
- The Tragedy: At around 2:30 a.m. on November 26, 1955, the ship sank due to heavy waves, resulting in the deaths of Primitivo Siccuan, Francisco Ricerra, Filoteo Siccuan, and Domingo Batta.
- Claims Filed: The heirs and dependents of the deceased filed claims with the Workmen's Compensation Commission, which awarded compensation to the claimants. The awards were affirmed by the Commission en banc.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- Jurisdiction: The Regional Offices of the Department of Labor had jurisdiction over workmen's compensation claims under Reorganization Plan 20-A, as the plan merely reallocated powers already vested in the Department of Labor.
- Employer-Employee Relationship: The existence of an employer-employee relationship is a jurisdictional foundation for recovery under the Workmen's Compensation Law. The Court ruled that the pilots and their assistants were employees of Madrigal Shipping Co., as their services were integral to the ship's operation and were performed under the control and direction of the petitioner.
- Liberal Construction of the Law: The Workmen's Compensation Law should be construed liberally in favor of employees and their dependents. All doubts regarding the right to compensation should be resolved in favor of the employees.
- Dependency: The Court deferred to the factual findings of the Workmen's Compensation Commission regarding the dependency of the claimants, as these findings were supported by evidence.