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Manahan vs.

Employees Compensation Commission


This is a petition to review the case of Maria Manahan vs. GSIS & Las Pinas Municipal Highschool
wherein the court affirmed GSIS from denial of claim benefit.

Maria E. Manahan, the petitioner, is the widow of Nazario Manahan, Jr., who died of "Enteric Fever" while
employed as classroom teacher in Las Pias Municipal High School. She filed a claim with the GSIS for
death benefit which was denied on the grounds that the ailment of Nazario Manahan, Jr., typhoid fever, is
not an occupational disease.

Maria filed a motion for reconsideration and contested that her husband was in perfect health when
admitted to the service and his ailment was attributable to his employment. But the GSIS affirmed its
decision based on that enteric fever or paratyphoid is similar in effect to typhoid fever, in the sense that
both are produced by Salmonella organisms.

An appeal was filed to ECC which affirmed the decision of GSIS finding that the ailment was not induced
by or aggravated by the nature of the duties of deceased as a teacher.

Whether the petitioner is entitled to claim benefit for her husbands death.
In case of doubt, the issue should be resolved in favor of the worker, and that social legislations like the
Workmen's Compensation Act and the Labor Code should be liberally construed to attain their laudable objective,
which is to give relief to the workman and/or his dependents in the event that the former should die or sustain an
Thus, the decision of the ECC sought to be reviewed is hereby set aside the GSIS is ordered:
1. To pay the petitioner the amount of SIX THOUSAND PESOS (P6,000.00) as death compensation
2. To pay the petitioner the amount of SIX HUNDRED PESOS (P600.00) as attorney's fees;
3. To reimburse the petitioner expenses incurred for medical services, hospitalization and medicines of the
deceased Nazario Manahan, Jr., duly supported by proper receipts; and
4. To pay administrative fees.
Prepared by:
Ara Rombawa

Domina N . Villavert vs. Employees' Compensation Commission & Government Service System
G.R. No. L-48605 December 14, 1981
Statutory Doctrine:
Labor laws are to be construed liberally in favor of the employees. Further, Article 4 of the. Labor Code provides
that, "All doubts in the implementation and interpretation of this Code, including its implementing rules and
regulations shall be resolved in favor of labor."
The late Marcelino Villavert, who was employed as a code verifier in the Philippine Constabulary ("PC"), died of
acute hemorrhagic pancreatitis on December 12, 1975. her mother, Domna Villavert, filed a claim for income
benefits for the death of the her son under PD No. 626 as amended with the Government Service Insurance System
("GSIS") on March 18, 1976.
However, her claim was denied by the GSIS on the ground that the acute hermorrhagic pancreatitis is not an
occupational disease and that the the petitioner failed to show the causal connection between the fatal ailment of
Marcelino and the nature of his employment.
It's was shown in the record that Marcelino did not only perform duties as a code verifier, but also served as
computer operator and clerk typist due to lack of manpower in the PC. On the day prior to his death, he was required
to do an overtime service until late in the evening after a whole day of strenuous activities. He went home home
without taking his meal. Shortly, he was gasping for breath, perspiring profusely and mumbling incoherent words.
He was rushed to the UE. Ramon Magsaysay Hospital where he was pronounced dead at 5:30 A.M. Of the following
Whether or not Domna Villavert is entitled to her son's income benefits?
NBI's medico legal stated that the cause of hemorrhagic pancreatitis is still unknown despite extensive researches in
this field, although most research data are agreed that physical that physical and mental stresses that the cause of
death of Marcelino Villavert was directly caused or at least aggravated by the duties he performed as a code verifier,
computer operator and clerk typist of the PC.
There is no evidence that he had a bout of alcoholic intoxication, in connection to the claim of the respondents that
alcoholism causes such disease.
Therefore, judgment is hereby rendered ordering the GSIS to pay Domna Villavert death benefits in the amount of
Six Thousand Pesos (P 6,000.00)

Prepared by:
Dennis Herrera

GR L-64204

Petitioners entered into a Contract of Services with private respondent Security Agency whereby the latter
undertook to supply the former with security guards. Private Complainants filed a complaint against the said
Security Agency for underpayment, non-payment of allowances and 13 th mo. Pay. Petitioner contended that
complainants have no cause of action for absence of employer-employee relationship between them. Private
respondent also denied its liability due to the inadequacy of amounts paid under the Contract of Services.
The Labor Arbiter rendered a decision dismissing the complaint against the herein petitioner for want of employeremployee relationship but ordering the Security Agency to pay the Complainants.
Security Agency then appealed to NLRC, which modified the decision of Labor Arbiter by holding that herein
petitioner be liable to pay complainants, jointly and severally, with the Security Agency.
Petition for certiorari was instituted contending that the NLRC erred in giving due course to the appeal.
The judgment was affirmed.
The rule on the construction of labor laws as provided for by Article 221 of the Labor Code "in any proceeding
before the Commission or any of the Labor Arbiters, the rules of evidence prevailing in Courts of law or
equity shall not be controlling and it is the spirit and intention of this Code that the Commission and its
members and the Labor Arbiters shall use every and an reasonable means to ascertain the facts in each case
speedily and objectively and without regard to technicalities of law or procedure, all in the interest of due
Petitioner's joint and several liability with the Security Agency was correctly adjudged. When petitioner entered into
a Contract of Services with the Security Agency and the latter hired complainants to work as guards for the former,
petitioner became an indirect employer of respondents-complainants pursuant to the unequivocal terms of Articles
106 and 107 of the Labor Code, as amended.

Prepared by:
Filipinas Silva-Astrero

Ty vs. First National Surety & Assurance Co. Inc.

G.R. No. L 161138
April 29, 1961
Diosdado Ty was employed as an operator mechanic foreman in the Broadway Cotton Factory. He insured himself
in 18 local insurance companies which issued to him personal accident policies. His beneficiary was his employer
Broadway Cotton Factory, which paid the insurance premiums. A fire broke out which totally destroyed the Factory.
Plaintiff was injured on the left hand by a heavy object He underwent medical treatment. Physical injuries have
caused temporary total disability of plaintiffs left hand Plaintiff Ty filed notice of accident and notice of claim to
recover indemnity under their insurance policy: Partial Disability Loss of: Either hand The loss of a hand shall
mean the loss by amputation through the bones of the wrist Defendants rejected plaintiffs claim Contention of
defendant: There being no severance of amputation of the left hand, the disability suffered by him was not covered
by his policy Contention of plaintiff: In order that he may recover on the insurance policies for the loss of his left
hand, it is not necessary that there should be an amputation thereof, but that it is sufficient if the injuries prevent him
from performing his work or labor necessary in the pursuance of his occupation or business Total disability means
common prudence requires him to desist from transacting his business or renders him incapable of working.
Whether or not Plaintiff Ty may recover on the insurance policies issued to him for the loss of his left hand
We cannot go beyond the clear and express conditions of the insurance policies, all of which define partial disability
as loss of either hand by amputation. There was no such amputation in the case at bar, that the disability of plaintiffs
hand was merely temporary. The insurance policy is the law between the parties The terms of the policies are clear,
express and specific that only amputation of the left hand should be considered as a loss thereof An interpretation
that would include temporary disability not covered by the policy would be unwarranted.
Prepared by:

Nicole FillerDela Cruz vs. Capital Insurance

Eduardo de la Cruz, employed as a mucker in the Itogon-Suyoc Mines, Inc. in Baguio, was the holder of
an accident insurance policy "against death or disability caused by accidental means. On January 1, 1957, for the
celebration of the New Year, the Itogon-Suyoc Mines, Inc. sponsored a boxing contest for general entertainment
wherein Eduardo, a non-professional boxer participated. In the course of his bout with another non-professional
boxer of the same height, weight, and size, Eduardo slipped and was hit by his opponent on the left part of the back
of the head, causing Eduardo to fall, with his head hitting the rope of the ring. He was brought to the Baguio General
Hospital the following day. He died due to hemorrhage, intracranial. Simon de la Cruz, the father of the insured and
who was named beneficiary under the policy, thereupon filed a claim with the insurance company. The
Capital Insurance and Surety co., inc denied stating that the death caused by his participation in a boxing contest
was not accidental. RTC favored Simon.
Whether or not the cause of accident was accident.
Yes. Eduardo slipped which was unintentional. The terms "accident" and "accidental" as used in insurance
contracts, have not acquired any technical meaning and are construed by the courts in their ordinary and
common acceptation happen by chance or fortuitously, without intention and design, and which is unexpected,
unusual, and unforeseen event that takes place without one's foresight or expectation event. This event proceeds
from an unknown cause, or is an unusual effect of a known cause. Therefore, it was not expected where the death or
injury is not the natural or probable result of the insured's voluntary act, or if something unforeseen occurs in the
doing of the act which produces the injury. The resulting death is within the protection of policies insuring against
death or injury from accident while the participation of the insured in the boxing contest is voluntary. The injury was
sustained when he slid, giving occasion to the infliction by his opponent of the blow that threw him to the ropes of
the ring is not the fact that boxing is attended with some risks of external injuries. It does not make any injuries
received in the course of the game not accidental. In boxing as in other equally physically rigorous sports, such as
basketball or baseball, death is not ordinarily anticipated to result. If, therefore, it ever does, the injury or death can
only be accidental or produced by some unforeseen happening or event as what occurred in this case. Furthermore,
the policy involved herein specifically excluded from its coverage (e) Death or disablement consequent upon the
Insured engaging in football, hunting, pigsticking, steeplechasing, polo-playing, racing of any kind, mountaineering,
or motorcycling. Death or disablement resulting from engagement in boxing contests was not declared outside of the
protection of the insurance contract

Prepared by:
Clariza Reyes

Qua Chee Gan v. Law Union and Rock Insurance

GR L-4611, 17 December 1955

Before WWII, Qua Chee Gan, a merchant of Albay, owned 4 warehouses in Tabaco, Albay used for the storage of
stocks of copra and of hemp in which he dealt extensively. They had been, with their contents, insured with the
Insurance Company since 1937, and the lose made payable to the Philippine National Bank as mortgage of the hemp
and copra, to the extent of its interest. On 21 July 1940, fire of undetermined origin that broke out and lasted almost
one week, gutted and completely destroyed Bodegas Nos. 1, 3 and 4, with the merchandise stored therein. Plaintiffappellee informed the insurer by telegram on the same date. The insurance Company resisted payment, claiming
violation of warranties and conditions, filing of fraudulent claims, and that the fire had been deliberately caused by
the insured or by other persons in connivance with him. Qua Chee Gan, his brother Qua Chee Pao, and some
employees of his were indicted and tried in 1940 for the crime of arson but were acquitted by the trial court in a final
decision on 9 July 1941.
With the civil case, Qua Chee Gan instituted the action in 1940 with the Court of First Instance of Albay, seeking to
recover the proceeds of certain fire insurance policies totalling P370,000, issued by the Law Union & Rock
Insurance Co., Ltd., through its agent, Warner, Barnes & Co., Ltd., upon certain bodegas and merchandise of the
insured that were burned on 21 June 1940. The records of the original case were destroyed during the liberation of
the region, and were reconstituted in 1946. After a trial that lasted several years, the CFI rendered a decision in favor
of the plaintiff, ordering the insurance company to pay Qua Chee Gan the sum of P146,394.48 (1st cause of action),
P150,000 (2nd), P5,000 (3rd), P15,000 (4th) , and P40,000 (5th), each bearing 80% interest per annum in
accordance with Section 91 (b) of the Insurance Act from 26 September 1940, until each is paid, with costs against
the defendant. It also dismissed the complaint in intervention of PNB without costs. The Insurance Company
appealed directly to the Supreme Court. It contends that a warranty in a fire insurance policy prohibited the storage
in the premises of oils (animal and/or vegetable and/or mineral and their liquid products having a flash point below
300 degrees Fahrenheit. Gasoline, which has a flash point below 300 degrees Fahrenheit was stored therein.
Whether gasoline may be construed as oil to warrant the forfeiture of claims under the insurance policy.
The Hemp Warranty provisions relied upon by the insurer speaks of oils (animal and/or vegetable and/or mineral
and/or their liquid products having a flash point below 300 Fahrenheit, and is decidedly ambiguous and uncertain;
for in ordinary parlance, Oils mean lubricants and not gasoline or kerosene. By reason of the exclusive control
of the insurance company over the terms and phraseology of the contract, the ambiguity must be held strictly against
the insurer and liberally in favor of the insured, specially to avoid a forfeiture. There is no reason why the
prohibition of keeping gasoline in the premises could not be expressed clearly and unmistakably, in the language and
terms that the general public can readily understand, without resort to obscure esoteric expression. If the company
intended to rely upon a condition of that character, it ought to have been plainly expressed in the policy. Still, it is
well settled that the keeping of inflammable oils on the premises, though prohibited by the policy, does not void it if
such keeping is incidental to the business and according to the weight of authority, even though there are printed
prohibitions against keeping certain articles on the insured premises the policy will not be avoided by a violation of
these prohibitions, if the prohibited articles are necessary or in customary use in carrying on the trade or business

conducted on the premises. In the present case, no gasoline was stored in the burned bodegas, and that Bodega No.
2 which was not burned and where the gasoline was found, stood isolated from the other insured bodegas.
The Supreme Court found no reversible error in the judgment appealed from, thus affirming it; with costs against the

Prepared by:
Hannah Pentinio


, vs.
G. R. L-34382, July 20, 1983
On or about January 13, 1967, S. Kajikita & Co. on board the SS Eastern Jupiter, which is owned by
therespondent, from Osaka, Japan coils of Black Hot Rolled Copper Wires Rods. The shipment was covered by
Billof Lading with arrival notice to the Phelps Dodge Copper Products Corporation, the consignee. It was
alsoinsured with the plaintiff against all risks in the amount of P1,580,105.06. The coils discharged from the vessel
were in bad order, consisting of loose and partly cut coils which hadto be considered scrap. The plaintiff paid the
consignee under insurance the amount of P3,260.44 for theloss/damage suffered by the cargo. Plaintiff, a foreign
insurance company duly authorized to do business in thePhilippines, made demands for payment of the aforesaid
amount against the carrier and transportation companyfor reimbursement of the aforesaid amount, but each refused
to pay the same. The Eastern Shipping Lines filedits answer and denied the allegations of Paragraph I which refer to
the plaintiffs capacity to sue for lack of knowledge or information sufficient to form a belief as to the truth thereof.
Angel Jose Transportation, on theother hand, admitted the jurisdictional averments in paragraphs 1, 2 and 3 of the
heading parties.The Court of First Instance dismissed the complaint on the ground that the appellant had failed to
proveits capacity to sue. The petitioner then filed a petition for review on certiorari
Whether or not that the trial court erred in dismissing the finding that plaintiff-appellant has no capacityto sue.
The court held that the objective of the law is to subject the foreign corporation to the jurisdiction of our court. The
Corporation Law must be given reasonable, not an unduly harsh interpretation which does not hamper the
development of trade relations and which fosters friendly commercial intercourse among countries. Counsel for
appellant contends that at the time of the service of summons, the appellant had not yet been authorized to do
business. But, the lack of capacity at the time of the execution of the contracts was cured by the subsequent
registration is also strengthened by the procedural aspects of the case. The court find the general denials inadequate
to attack the foreign corporations lack of capacity to sue inthe light of its positive averment that it is authorized to do
so. Section 4, Rule 8 requires that "a party desiring to raise an issue as to the legal existence of any party or the
capacity of any party to sue or be sued in are presentative capacity shall do so by specific denial, which shall include
such supporting particulars as are particularly within the pleader's knowledge. At the very least, the private
respondents should have stated particulars in their answers upon which a specific denial of the petitioner's capacity
to sue could have beenbased or which could have supported its denial for lack of knowledge. And yet, even if the
plaintiff's lack of capacity to sue was not properly raised as an issue by the answers, the petitioner introduced
documentary evidence that it had the authority to engage in the insurance business at the time it filed the
complaints. The Supreme Court granted the petition, reversing the decision of the lower court

Prepared by:
Jayson Turaray

Read carefully and you will see

The correct order that they should be.
Once revealed, you'll know what they are about
You may use them, when in doubt. ;)

CLUE: The words in UPPER CASE are not in place.

Manahan vs ECC:

In case of RESOLVED, same should be LIBERALLY in favor of the DOUBT, and that WORKER legislation shoul
d be SOCIAL construed.

In case of DOUBT, same should be RESOLVED in favor of the WORKER, and that SOCIAL legislation should be LI
BERALLY construed.

Villavert vs ECC:

All FAVOR in the implementation and interpretation of this Code, including its implementing rules and regulations s

All DOUBTS in the implementation and interpretation of this Code, including its implementing rules and regulation
s shall be RESOLVED in FAVOR of LABOR.

Del Rosario vs NLRC:

The rules of INTENTION shall not be DUE PROCESS and it is the EVIDENCE and CONTROLLING of this Code
that the Commission and its members and Labor Arbiters shall use, without regard to technicalities of law or proced
ure, all in the interest of SPIRIT.

The rules of EVIDENCE shall not be CONTROLLING and it is the SPIRIT and INTENTION of this Code that the
Commission and its members and Labor Arbiters shall use, without regard to technicalities of law or procedure, all i
n the interest of DUE PROCESS.

Ty vs First National Surety:

The INSURANCE POLICIES contained in the LAW is the PARTIES between the AGREEMENT.

The AGREEMENT contained in the INSURANCE POLICIES is the LAW between the PARTIES.

Home Insurance vs Eastern Shipping Lines:

The Corporation Law must be given a reasonable DEVELOPMENT which does not hamper the INTERPRETATIO
N of COMMERCIAL INTERCOURSE and which fosters friendly TRADE RELATIONS among countries.

The Corporation Law must be given a reasonable INTERPRETATION which does not hamper the DEVELOPMEN
T of TRADE RELATIONS and which fosters friendly COMMERCIAL INTERCOURSE among countries.