136 SCRA 141 Political Law Separation of Powers SC Cannot Legislate; Exception

Statutory Construction Determining the Purpose of the Law

Perfecto Floresca et al are the heirs of the deceased employees of Philex Mining Corporation who, while
working at its copper mines underground operations in Tuba, Benguet on June 28, 1967, died as a result
of the cave-in that buried them in the tunnels of the mine. Theircomplaint alleges that Philex, in violation
of government rules and regulations, negligently and deliberately failed to take the required precautions
for the protection of the lives of its men working underground. Floresca et al moved to claim their benefits
pursuant to the Workmens Compensation Act before the Workmens Compensation Commission. They
also filed a separate civil case against Philex for damages.
Philex sought the dismissal of the civil case as it insisted that Floresca et al have already claimed benefits
under the Workmens Compensation Act.

ISSUE: Whether or not Philex is correct.

HELD: Yes. Under the law, Floresca et al could only do either one. If they filed for benefits under the WCA
then they will be estopped from proceeding with a civil case before the regular courts. Conversely, if they
sued before the civil courts then they would also be estopped from claiming benefits under the WCA.
HOWEVER, the Supreme Court ruled that Floresca et al are excused from this deficiency due to
ignorance of the fact. Had they been aware of such then they may have not availed of such a remedy.
But, if in case theyll win in the lower court whatever award may be granted, the amount given to them
under the WCA should be deducted. The SC emphasized that if they would go strictly by the book in this
case then the purpose of the law may be defeated. Idolatrous reverence for the letter of the law sacrifices
the human being. The spirit of the law insures mans survival and ennobles him. As Shakespeare said,
the letter of the law killeth but its spirit giveth life.