Topic.

Purpose of Construction: Limitation on the power of courts to construe

Case. Petition to review lower court decision dismissing a civil complaint lodged against Philex

Facts. It is alleged that prior to the accident, Philex failed to address safety concerns in the mining
site. Much water accumulated in an open pit area which caused pressure in the working shafts
below. As a result, said area collapsed. Out of 48, 5 escaped, 22 rescued within the week. But 21
were left to die due to Philex’s order to stop rescue mission.

Heirs of the 21 filed a civil complaint in CFI. Philex filed a motion to dismiss arguing that the
accident falls under the Workers’ Compensation Act (WCA) and thus outside of CFI jurisdiction.
WCA provides that (1) such work-connected deaths are within the jurisdiction of Workmen’s
Compensation Commission (WCC) and (2) if the employer is negligent, employer shall pay the
compensation plus 50% of same compensation. But in essence, the respondents invoke Section
5 of the WCA which states: “Exclusive right to compensation — The rights and remedies granted
by this Act to an employee by reason of a personal injury entitling him to compensation shall
exclude all other rights and remedies accruing to the employee, his personal representatives,
dependents or nearest of kin against the employer under the Civil Code and other laws because
of said injury.” Because the heirs have already received compensation, they are no longer entitled
to a damage suit.

The heirs of the deceased filed the present petition.

Issue. (1) Does CFI has jurisdiction? -Yes

(2) Whether the petitioners can only avail of WCA action or have a choice between WCA action
and civil damage in regular court or can avail of both WCA and civil damage? –Choose either one
but not both.

Ratio. To answer the two issues, (2) should be addressed before (1). (2) Generally, petitioners
must choose between a WCA action and civil suit. This is what the Section 5 of WCA provides
and what has been applied in various court decisions. But the court decided to render leeway to
the petitioners given the peculiarity of the instances. Petitioners have already received
compensation under the WCA. Afterwards, they learned of the true cause of the accident which
was Philex’s negligence. And then they filed a civil suit. The court reasoned that had the
petitioners learned of the cause much sooner, petitioners would have filed for a civil suit instead.
Petitioners’ initial resort to WCA action, the court said, is based on ignorance or mistake of fact.
Because petitioners were not informed of the true cause, they had not the choice between a WCA
and a civil suit. This then creates an exception to Section 5 of WCA. Hence, court remanded the
case to lower court for proper judgment. (1) CFI now has jurisdiction because of the court’s making
an exception of the case.

Doctrine: The topic, limitation on the power of courts to construe, can be found within court’s
discussion of the second issue. The two dissenting opinions posit that a careful reading of Section
5 of WCA would demonstrate that when a complainant has already availed of compensation via
WCA, his/her right to sue in civil or other courts are understood to have been extinguished. After
passage of WCA, legislature had plenty of occasion to modify relevant provision but did not do
so. This, according to dissent, is manifest of legislative’s continuing intent to retain the exclusivity
provided therein. In the majority opinion’s decision to allow petitioners to file case despite having
received their WCA compensation, dissent argues that the court has exercised a power outside
of its capacities, i.e. that it has legislated.

To this, the majority opinion enunciates that it has not legislated. What it did was a mere
implementation of the Constitution and relevant statutes. Secs. 6, 7, and 9 of Art. II of 1973
Constitution guarantees social justice, establishes adequate services in employment, and
protects labor. With these provisions, the present court only gave effect to the rights petitioners
are entitled to. No legislation occurred, because the principles are already present and need only
be applied.