Construction in Labor Laws

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Reviewer for Statutory Construction by Chester Cabalza

Rule on the construction of labor laws

1. Manahan v. ECC

This Court applied the provisions of the Workmen’s Compensation Act, as amended, on passing upon petitioner’s claim. The illness that claimed the life of the deceased may have its onset before 10 December 1974, thus, his action accrued before 10 December 1974. Still, in any case, and in case of doubt, the same 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, i.e., to give relief to the workman and/or his dependents in the event that the former should die or sustain an injury. Pursuant to such doctrine and applying now the provisions of the Workmen’s Compensation Act in this case, the presumption of compensability subsists in favor of the claimant.

2. Villavert v. ECC

From the foregoing facts of record, it is clear that Marcelino N. Villavert died of acute hemorrhagic pancreatitis which was directly caused or at least aggravated by the duties he performed as code verifier, computer operator and clerk typist of the Philippine Constabulary. Further, Article 4 of the Labor Code of the Philippines, as amended, 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.”

3. Del Rosario & Sons v. NLRC

Articles 106 of the Labor Code provides that “in the event that the contractor or subcontractor fails to pay the wages of his employees in accordance with this Code, the employer shall be jointly and severally liable with his contractor or subcontractor to such employees to the extent of the work performed under the contract, in the same manner and extent that he is liable to employees directly employed by him,” and Article 107 provides that “the provisions of the immediately preceding Article shall likewise apply to any person, partnership, association or corporation which, not being an employer, contracts with an independent contractor for the performance of any work, task, job or project.” The Supreme Court affirmed the judgment under review, without prejudice to petitioner’s right to seek reimbursement from Calmar Security Agency for such amounts as petitioner may have to pay to complainants.