11. Liwanag vs. Workmen Compensation Commission

LIWANAG VS. WORKMEN’S COMPENSATION COMMISSION May 22, 1959 G.R. No. L-12164

FACTS: The Security Guard Balderama of Liwanag Auto Supply owned by Benito Liwanag and Maria Liwanag Reyes was killed while on duty. is heirs in due time filed a claim for  compen compensat sation ion with with the !orkme !orkmen"s n"s #ompen #ompensat sation ion #ommis #ommissio sion$ n$ which which was granted granted.. %t ordered Benito and Maria to pay the amount due &ointly and se'erally. se'erally.  Appellants appealed the case for the sole reason that according to them$ the compensation is di'isible$ as such$ the responsibility of appellants should only be &oint.

ISSUE: Whether or not the liability of partners arising from compensable injury or death of an employee should be joint !E"#: $o The pro%isions of the ne& Ci%il Code ta'en together &ith those of  Section ( of the Wor'men)s Compensation Act* reasonably indicate that in compensation cases* the liability of business partners* li'e appellants* should be solidary+ other&ise* the right of the employee may be defeated* or at least crippled If the responsibility of appellants &ere to be merely joint and solidary* and one of them happens to be insol%ent* the amount a&arded to the appellees &ould only be partially satis,ed* &hich is e%idently contrary to the intent and purposes of the Act In the pre%ious cases &e ha%e already held held that that the Wor'me or'men)s n)s Compen Compensat sation ion Ac Actt should should be constr construed ued fairl fairly* y* reasonably and liberally in fa%or of and for the bene,t of the employee and his dependents+ that all doubts as to the right of compensation resol%ed in his his fa%o fa%or+ r+ and and that that it sh shou ould ld be inte interp rprreted eted to prom promot ote e its its purp purpos ose e Accor Ac cordin dingly gly** the prese present nt contr contro%e o%ersy rsy should should be decide decided d in fa%or fa%or of the appellees Sinc Since e the the Wor'm or'men en)s )s Comp Compen ensa sati tion on Act &as &as enac enacte ted d to gi%e gi%e full full prot protec ecti tion on to the the empl employ oyee ee** reaso eason n dema demand nds s that that the the natu naturre of the the obli obliga gati tion on of the the empl employ oyer ers s to pay comp compen ensat satio ion n to the the heir heirs s of thei theirr employee &ho died in line of duty* should be solidary+ other&ise* the purpose of the la& could not be attained