Labor Principles

GOVERNMENT SERVICE INSURANCE SYSTEM, PETITIONER, VS.
JOSE
M. CAPACITE, RESPONDENT.
G.R. No. 199780, September 24, 2014
Working Conditions for Special Groups of Employees
BRION, J.:
While item 17, Annex "A" of the Amended Rules of Employee's Compensation
considers lung cancer to be a compensable occupational disease, it likewise provides
that the employee should be employed as a vinyl chloride worker or a plastic worker. In
this case, however, Elma did not work in an environment involving the manufacture of
chlorine or plastic, for her lung cancer to be considered an occupational disease.
[13]
There was, therefore, no basis for the CA to simply categorize her illness as an
occupational disease without first establishing the nature of Elma's work. Both the law
and the implementing rules clearly state that the given alternative conditions must be
satisfied for a disease to be compensable.
ZAIDA G. RARO, petitioner v. EMPLOYEES' COMPENSATION

COMMISSION and GOVERNMENT SERVICE INSURANCE SYSTEM
G.R. No. L-58445, April 27, 1989
GUTIERREZ, JR., J.:
The Court saw no arbitrariness in the Commission's allowing vinyl chloride

workers or plastic workers to be compensated for brain cancer. What the law requires for others is
proof. The law, as it now stands requires the claimant to prove a positive thing
The illness was caused by employment and the risk of contracting the disease is
increased by the working conditions. To say that since the proof is not available,
therefore, the trust fund has the obligation to pay is contrary to the legal requirement that proof
must be adduced. The existence of otherwise non-existent proof cannot be presumed. The
Court has recognized the validity of the present law and has granted and rejected claims
according to its provisions. We find in it no infringement of the worker's constitutional
rights
GOVERNMENT SERVICE INSURANCE SYSTEM (GSIS) v. JAIME A.

VALENCIANO,
G.R. No. 168821, April 10, 2006
Government Guarantee
YNARES-SANTIAGO, J.:
Section 1 (b), Rule III of the Rules Implementing PD No. 626, as amended, states
that for the sickness and the resulting disability or death to be compensable, the same
must be the result of an occupational disease listed under Annex "A" with the conditions
set therein satisfied; otherwise, proof must be shown that the risk of contracting the
disease is increased by the working conditions.
Diabetes mellitus, is a non-occupational disease, hence not compensable. Jaime
A. Valenciano’s hypertension is held to be directly connected to his primary ailment,
diabetes mellitus, and therefore non-compensable.
The degree of proof required under P.D. No. 626 is merely substantial evidence,
which means, "such relevant evidence as a reasonable mind might accept as adequate to
support a conclusion." What the law requires is a reasonable work-connection and not a
direct causal relation. It is enough that the hypothesis on which the workmen's claim is
based is probable. Medical opinion to the contrary can be disregarded especially where
there is some basis in the facts for inferring a work-connection. Probability, not
certainty, is the touchstone. While claimant must adduce substantial evidence that the
risk of contracting the illness is increased by the working conditions to which an
employee is exposed to, we cannot close our eyes to any reasonable work-related
connection of the worker’s ailment and his employment.
Any doubt on this matter has to be interpreted in favor of the employee,
considering that P.D. No. 626 is a social legislation.
AMBASSADOR HOTEL, INC. v. SOCIAL SECURITY SYSTEM

G.R. No. 194137, June 21, 2017
Ambassador Hotel is obligated to remit SSS contributions
MENDOZA, J.:
Under Section 8(c) of R.A. No. 8282, an employer is defined as "any person,
natural or juridical, domestic or foreign, who carries on in the Philippines any trade,
business, industry, undertaking, or activity of any kind and uses the services of another
person who is under his orders as regards the employment, except the Government and
any of its political subdivisions, branches or instrumentalities, including corporations
owned or controlled by the Government." Ambassador Hotel, as a juridical entity, is still
bound by the provisions of R.A. No. 8282. Section 22 (a) thereof states:
Remittance of Contributions, (a) The contributions imposed in the preceding section
shall be remitted to the SSS within the first ten (10) days of each calendar month
following the month for which they are applicable or within such time as the
Commission may prescribe. Every employer required to deduct and to remit such
contributions shall be liable for their payment and if any contribution is not paid to the
SSS as herein prescribed, he shall pay besides the contribution a penalty thereon of
three percent (3%) per month from the date the contribution falls due until paid. If
deemed expedient and advisable by the Commission, the collection and remittance of
contributions shall be made quarterly or semi-annually in advance, the contributions
payable by the employees to be advanced by their respective employers: Provided, that
upon separation of an employee, any contribution so paid in advance but not due shall
be credited or refunded to his employer.
Verily, prompt remittance of SSS contributions under the aforesaid provision is

mandatory. Any divergence from this rule subjects the employer not only to monetary
sanctions, that is, the payment of penalty of three percent (3%) per month, but also to
criminal prosecution if the employer fails to: (a) register its employees with the SSS; (b)
deduct monthly contributions from the salaries/wages of its employees; or (c) remit to
the SSS its employees' SSS contributions and/or loan payments after deducting the
same from their respective salaries/wages.
JORGE NAVARRA V. PEOPLE OF THE PHILIPPINES

G.R. NO. 224943, MARCH 20, 2017
Section 22 (a) of RA 8282
PERLAS-BERNABE, J.:
Section 22. Remittance of Contributions. - (a) The contributions imposed in the

preceding section shall be remitted to the SSS within the first ten (10) days of each
calendar month following the month for which they are applicable or within such time
as the Commission may prescribe. Every employer required to deduct and to remit such
contributions shall be liable for their payment and if any contribution is not paid to the
SSS as herein prescribed, he shall pay besides the contribution a penalty thereon of
three percent (3%) per month from the date the contribution falls due until paid. If
deemed expedient and advisable by the Commission, the collection and remittance of
contributions shall be made quarterly or semi-annually in advance, the contributions
payable by the employees to be advanced by their respective employers: Provided, That
upon separation of an employee, any contribution so paid in advance but not due shall
be credited or refunded to his employer.
Verily, prompt remittance of SSS contributions under the aforesaid provision

is mandatory.36 Any divergence from this rule subjects the employer not only to
monetary sanctions, i.e. the payment of penalty of three percent (3%) per month, but
also to criminal prosecution if the employer fails to: (a) register its employees with the
SSS; (b) deduct monthly contributions from the salaries/wages of its employees; or (c)
remit to the SSS its employees' SSS contributions and/or loan payments after deducting
the same from their respective salaries/wages.37 In this regard, Section 28 (f) of RA 8282
explicitly provides that "[i]f the act or omission penalized by this Act be committed by
an association, partnership, corporation or any other institution, its managing head,
directors or partners shall be liable to the penalties provided in this Act for the offense."
Notably, the aforesaid punishable acts are considered mala prohibita and, thus, the
defenses of good faith and lack of criminal intent are rendered immaterial
KUKAN INTERNATIONAL CORPORATION VS HON. AMOR REYES

G.R. No. 182729, September 29, 2010
Doctrine of Immutability and Inalterability of Judgment
VELASCO, JR., J.:
It is an elementary principle of procedure that the resolution of the court in a

given issue as embodied in the dispositive part of a decision or order is the controlling
factor as to settlement of rights of the parties. Once a decision or order becomes final
and executory, it is removed from the power or jurisdiction of the court which rendered
it to further alter or amend it. It thereby becomes immutable and unalterable and any
amendment or alteration which substantially affects a final and executory judgment is
null and void for lack of jurisdiction, including the entire proceedings held for that
purpose. An order of execution which varies the tenor of the judgment or exceeds the
terms thereof is a nullity.
Deeply ingrained in our jurisprudence is the principle that a decision that has
acquired finality becomes immutable and unalterable. As such, it may no longer be
modified in any respect even if the modification is meant to correct erroneous
conclusions of fact or law and whether it will be made by the court that rendered it or by
the highest court of the land.
The only exceptions to the general rule are the correction of clerical errors, the
so-called nunc pro tunc entries which cause no prejudice to any party, void judgments,
and whenever circumstances transpire after the finality of the decision which render its
execution unjust and inequitable.
How Courts Acquire Jurisdiction in Civil Cases

Courts acquire jurisdiction over the plaintiffs upon the filing of the complaint. On
the other hand, jurisdiction over the defendants in a civil case is acquired either through
the service of summons upon them or through their voluntary appearance in court and
their submission to its authority.
Principle of Piercing the Veil of Corporate Fiction
This principle finds its context on the postulate that a corporation is an artificial
being invested with a personality separate and distinct from those of the stockholders
and from other corporations to which it may be connected or related.
Under the doctrine of "piercing the veil of corporate fiction," the court looks at
the corporation as a mere collection of individuals or an aggregation of persons
undertaking business as a group, disregarding the separate juridical personality of the
corporation unifying the group. Another formulation of this doctrine is that when two
business enterprises are owned, conducted and controlled by the same parties, both law
and equity will, when necessary to protect the rights of third parties, disregard the legal
fiction that two corporations are distinct entities and treat them as identical or as one
and the same.
Whether the separate personality of the corporation should be pierced hinges on

obtaining facts appropriately pleaded or proved. However, any piercing of the corporate
veil has to be done with caution, albeit the Court will not hesitate to disregard the
corporate veil when it is misused or when necessary in the interest of justice.
BENITO ARATEA and PONCIANA CANONIGO, Petitioners, vs.

ESMERALDO P. SUICO and COURT OF APPEALS, Cebu City, Respondents.
G.R. No. 170284, March 16, 2007
GARCIA, J.:
In MAM Realty Development Corporation v. NLRC, the Court stated:

A corporation is a juridical entity with legal personality separate and
distinct from those acting for and in its behalf and, in general, from the
people comprising it. The general rule is that obligations incurred by the
corporation, acting through its directors, officers and employees, are its
sole liabilities. There are times, however, when solidary liabilities may be
incurred but only when exceptional circumstances warrant such as in the
following cases:
1. When directors and trustees or, in appropriate cases, the officers of a corporation:
(a) vote for or assent to patently unlawful acts of the corporation;
(b) act in bad faith or with gross negligence in directing the
corporate affairs;
(c) are guilty of conflict of interest to the prejudice of the corporation, its
stockholders or members, and other persons;
2. When a director or officer has consented to the issuance of watered stocks or who,
having knowledge thereof, did not forthwith file with the corporate secretary his
written objection thereto;
3. When a director, trustee or officer has contractually agreed or stipulated to hold
himself personally and solidarily liable with the corporation; or
4. When a director, trustee or officer is made, by specific provision of law, personally
liable for his corporate action.
In labor cases, particularly, corporate directors and officers are solidarily liable
with the corporation for the termination of employment of corporate employees
done with malice or in bad faith.
GOVERNMENT SERVICE INSURANCE SYSTEM V. ESTEVES

G.R. No. 182297, June 21, 2017
Health Assessment
VELASCO, JR., J.:
Evidence must be presented to show a history of any trauma to the head at work.
There was never any evidence of this. There was never any mention of any head trauma
that the deceased suffered. There being no evidence of trauma, the connection to the
brain hemorrhage cannot be established. As to his hypertension, the ECC found that he
did not have any history and that it caused impairment of the function of body organs
like kidneys, heart, eyes and brain. None of the medical reports had established the
same. Evidently, the death of Emilio cannot be concluded as compensable.
GOVERNMENT SERVICE INSURANCE SYSTEM V. CALUMPIANO

G.R. No. 196102, November 26, 2014
Health Assessment
DEL CASTILLO, J.:
In general, a covered claimant suffering from an occupational disease is

automatically paid benefits. However, although cerebro-vascular accident and essential
hypertension are listed occupational diseases, their compensability requires compliance
with all the conditions set forth in the Rules. In short, both are qualified occupational
diseases. For cerebro-vascular accident, the claimant must prove the following: (1) there
must be a history, which should be proved, of trauma at work (to the head specifically)
due to unusual and extraordinary physical or mental strain or event, or undue exposure
to noxious gases in industry; (2) there must be a direct connection between the trauma
or exertion in the course of the employment and the cerebro-vascular attack; and (3) the
trauma or exertion then and there caused a brain hemorrhage. On the other hand,
essential hypertension is compensable only if it causes impairment of function of body
organs like kidneys, heart, eyes and brain, resulting in permanent disability, provided
that, the following documents substantiate it: (a) chest X-ray report; (b) ECG report; (c)
blood chemistry report; (d) funduscopy report; and (e) C-T scan.

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GOVERNMENT SERVICE INSURANCE SYSTEM, PETITIONER, VS.

Working Conditions for Special Groups of Employees

ZAIDA G. RARO, petitioner v. EMPLOYEES' COMPENSATION

Working Conditions for Special Groups of Employees

GUTIERREZ, JR., J.:

The Court saw no arbitrariness in the Commission's allowing vinyl chloride

GOVERNMENT SERVICE INSURANCE SYSTEM (GSIS) v. JAIME A.

AMBASSADOR HOTEL, INC. v. SOCIAL SECURITY SYSTEM

Ambassador Hotel is obligated to remit SSS contributions

Verily, prompt remittance of SSS contributions under the aforesaid provision is

JORGE NAVARRA V. PEOPLE OF THE PHILIPPINES

Section 22. Remittance of Contributions. - (a) The contributions imposed in the

Verily, prompt remittance of SSS contributions under the aforesaid provision

KUKAN INTERNATIONAL CORPORATION VS HON. AMOR REYES

Doctrine of Immutability and Inalterability of Judgment

VELASCO, JR., J.:

It is an elementary principle of procedure that the resolution of the court in a

How Courts Acquire Jurisdiction in Civil Cases

Principle of Piercing the Veil of Corporate Fiction

Whether the separate personality of the corporation should be pierced hinges on

BENITO ARATEA and PONCIANA CANONIGO, Petitioners, vs.

Working Conditions for Special Groups of Employees

In MAM Realty Development Corporation v. NLRC, the Court stated:

GOVERNMENT SERVICE INSURANCE SYSTEM V. ESTEVES

VELASCO, JR., J.:

GOVERNMENT SERVICE INSURANCE SYSTEM V. CALUMPIANO

DEL CASTILLO, J.:

In general, a covered claimant suffering from an occupational disease is

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