Case Summary (G.R. No. L-28694)
Factual Background
Pacifico L. Gatus was employed by UMACOR as a Purchasing Agent and was detailed to TESCO from May 16, 1965, until his return to UMACOR on August 1, 1965. He contracted an illness on January 13, 1967, returning to work briefly before his death on July 14, 1967, from liver cirrhosis with malignant degeneration. His widow, Leonila S. Gatus, filed a claim for compensation alleging that the illness was work-related while he was employed at TESCO.
Procedural History
The Workmen’s Compensation Section of the Quezon City office rendered an award in favor of the Gatus heirs on October 6, 1967, ordering TESCO to pay death benefits and burial expenses. TESCO's appeal process began with a notification indicating non-conformity to the award by asserting a lack of employer-employee relationship, contending that Gatus was employed by UMACOR, not TESCO.
Key Issues Raised
TESCO raised several critical arguments:
- The Workmen’s Compensation Commission lacked jurisdiction to make an award since there was no employer-employee relationship.
- The claim of jurisdictional absence should be upheld since jurisdiction cannot be conferred by the parties' actions.
- The Supreme Court has jurisdiction to annul the award made by the Commission.
Jurisdictional Concerns
The legal foundation for any compensation claim is the existence of an employer-employee relationship. TESCO's assertion that no such relationship existed with Gatus is viewed as a defense that should have been raised during the proceedings before the Commission. The question of whether Gatus was an employee of TESCO is primarily factual and binding, thereby limiting the Supreme Court's scope of review.
Admission of Employer-Employee Relationship
In prior communications and requests for extensions, TESCO represented itself as the employer of the deceased Gatus. The change in TESCO's position during the petition was recognized as an afterthought, undermining its credibility. Courts maintain the principle that the corporate veil may be pierced when it is used to obstruct justice or evade obligations.
Remedies Available
The petition for Certiorari was deemed prematurely filed as TESCO did not exhaust all procedural remedies available under the Workmen's Compensation rules, namely an appeal to the Commission or a
...continue readingCase Syllabus (G.R. No. L-28694)
Case Background
- The case stems from Certiorari proceedings involving the petitioner, Telephone Engineering and Services Company, Inc. (TESCO), and respondents including the Workmen's Compensation Commission and the heirs of the deceased employee, Pacifico L. Gatus.
- An award was rendered against TESCO on October 6, 1967, by the Acting Referee in favor of Leonila S. Gatus and her children, claiming compensation for the death of Pacifico L. Gatus, who had worked under UMACOR and was detailed to TESCO at one point.
- TESCO contested the award, asserting that there was no employer-employee relationship between them and the deceased.
Parties Involved
- Petitioner: Telephone Engineering and Services Company, Inc. (TESCO), a domestic corporation engaged in manufacturing telephone equipment.
- Respondents: Workmen's Compensation Commission, Provincial Sheriff of Rizal, and Leonila Santos Gatus, acting on behalf of her minor children Teresita, Antonina, and Reynaldo Gatus.
Employment History of Deceased
- Pacifico L. Gatus was employed by UMACOR as a Purchasing Agent starting September 8, 1964, and was detailed to TESCO on May 16, 1965, before returning to UMACOR on August 1, 1965.
- He contracted an illness on January 13, 1967, returned to work on May 10, 1967, but died on July 14, 1967, due to liver cirrhosis.
Legal Proceedings Initiated
- On August 7, 1967, Leonila S. Gatus filed a "Notice and Claim for Compensation" with