Case Summary (G.R. No. 270317)
Summary of Events
On April 16, 1951, Carbajosa, while working as an apprentice in Asia Steel Corporation, was injured when his hand was caught in a running machine while attempting to tighten a belt. This incident led to the amputation of both of his feet. Following his hospitalization, which Asia Steel Corporation covered, he sought workers' compensation. The referee awarded him ₱2,246.40 after determining the accident arose from his employment.
Legal Issues Raised
Asia Steel Corporation contested the Commission's decision on two grounds: (1) Carbajosa was not considered an employee or laborer, and (2) he was negligent, contributing to his own injuries. However, the second argument regarding negligence was not properly presented in their motion to dismiss at the Commission level, rendering the petition's focus limited to the employment status of Carbajosa.
Commission Findings on Employment
The Commission concluded that Carbajosa was, in fact, an employee of Asia Steel Corporation at the time of the accident. Carbajosa had gone to the factory seeking employment after being introduced by a coworker. After a brief interview, he was directed to begin working under Kim, who represented himself as authorized to employ workers for the factory, acting on behalf of the manager.
Authority of the Factory Manager
The petitioner argued that since only Yu Kong Tiong, as President, had the authority to hire employees, Kim's actions should not bind the corporation. However, the Commission found that Kim had apparent authority to engage employees under the circumstances, as Tiong allowed Kim to manage the factory on a day-to-day basis. The relationship of employer-employee was established because Carbajosa was told to work by the individual in charge who represented that he had Tiong’s authority.
Legal Precedents and Analogies
The decision referenced precedents emphasizing that apparent authority of agents can create employment relationships for compensation purposes. The employer-employee relationship is vital for compensation claims, often assessed through the realities of employment practices rather than strict legal formalities.
Additional Considerations
The evidence presented indicated that the acti
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Case Overview
- This case involves a petition for review of an order from the Workmen’s Compensation Commission that approved an award for compensation to Ismael Carbajosa, a laborer who suffered serious injuries while working for Asia Steel Corporation.
- The incident occurred on April 16, 1951, when Carbajosa was injured while attempting to tighten a belt on a running machine, leading to the amputation of both feet.
Background of the Incident
- Ismael Carbajosa was working at the Asia Steel Corporation’s factory in Grace Park, Manila, when the accident took place.
- The accident happened shortly after Carbajosa began his employment as an apprentice, which he secured through an acquaintance.
- The injuries sustained were severe enough to necessitate immediate hospitalization, and the corporation covered these medical expenses.
Findings of the Referee
- The referee determined that Carbajosa was indeed employed as an apprentice and that the accident arose out of this employment.
- The referee ordered Asia Steel Corporation to indemnify Carbajosa in the amount of ₱2,246.40 and to pay the associated costs.
Legal Contentions by the Petitioner
- Asia Steel Corporation contested the ruling based on two primary arguments:
- First, that Ismael Carbajosa was not an employee or laborer of the corporation.
- Second, that the accident was caused by Carbajosa's own fault and negligence, a contention that had not been raised in the motion to dismiss nor addressed by the referee or