EXTRINSIC AIDS
As evidenced by the increasing numbers of court decisions which involve statutes,' and by the
large and continually growing literature in the field, the subject of statutory interpretation is one
of the most important in modern law. Although it is a field in which exact rules of automatic
application can very seldom be formulated, only recently a member of the Supreme Court
pointed out the great need for a set of "consistently accepted principles of interpretation." Since
the primary purpose of all statutory interpretation is to ascertain the meaning and to effectuate
the purposes of the legislature, and since words are merely symbols without inherent meaning,
every statute upon which a court is required to rule must, in some sense, be construed and
interpreted.
Escosura v. San Miguel
Brewery, Inc.
PETITIONERS-APPELLEES - LUCIANO ESCOSURA, DIONISIO ASIS,
PRIMITIVO BINALBER, PROCOPIO CIPRIANO, FEDERICO HIPOLITO, CESAR
VILLAREAL, and PABLO R. CRUZ
RESPONDENT-APPELLANT - SAN MIGUEL BREWERY, INC.
NATURE OF THE CASE
From the Resolution of the Social Security Commission (in SSC Cases Nos. 33, 37,
38, 39, 40, 41 and 42) directing the San Miguel Brewery, Inc. to pay the claims for
sickness benefit allowances of Dionisio Asis, Primitivo Binalber, Procopio Cipriano,
Florencio Hipolito, Cesar Villareal, Luciano Escosura, and Pablo R. Cruz, said
company appealed to this Court under the provisions of Section 5 (c) of Republic Act
1161, as amended, there being no question of fact involved.
Section 5 (c) of Republic Act 1161
Court review.—The decision of the Commission upon any disputed matter may be reviewed both
upon the law and the facts by the Court of Appeals. For the purpose of such review the procedure
concerning appeals from the Court of First Instance shall be followed as far as practicable and
consistent with the purposes of this Act. Appeal from a decision of the Commission must be taken
within fifteen days from notification of such decision. If the decision of the Commission involves
only questions of law, the same shall be reviewed by the Supreme Court. No appeal bond shall be
required. The case shall be heard in a summary manner, and shall take precedence over all cases,
except that in the Supreme Court, criminal cases wherein life imprisonment or death has been
imposed by the trial court shall take precedence. No appeal shall act as a supersedeas or a stay of the
order of the Commission, unless the Commission itself, or the Court of Appeals, or the Supreme
Court, shall so order.
STATUTE: Grants employee ―leaves of absence with pay
FACTS:
Petitioners are employees of San Miguel Respondent Corporation who at
various times during employment, fell ill. They were given sick leave pay
pursuant to its Health, Welfare and Retirement Plan. Despite receipt of
the sick leave pay from Respondent Corporation, the employees claimed
for sickness benefit allowances under the Social Security Act contending
that their receipt of sick leave pay of less than the full wage does not
preclude them from claiming for the allowances provided in the law.
Respondent Corporation countered that having already received sick
leave pay, they cannot claim benefits under the Social Security Act as
these are exclusive to those not receiving any leave privileges at all from
the employer.
ISSUE:
W/N Petitioners were entitled to additional sickness benefit allowance
under the Social Security Act.
HELD:
To uphold the theory that as long as the employee receives any
amount as sick leave pay by a private benefit plan, the employee
cannot avail of the privileges under the Social Security Act, would be
to enable the employer to defeat the purpose of the law. The Social
Security Act, having been enacted for the welfare of the employees,
cannot be given an interpretation that would defeat such purpose.
It is also contended for the respondent-employer that if the phrase in question be interpreted to
mean full pay, an employee could receive more benefits when sick than when he is well and renders
service, thereby imposing upon the employer an additional burden. Under the facts of the cases at
bar, and the provisions of the law applicable thereto, the respondent Company would not be
required to pay more than the employee's full wage. Under its private benefit plan, the most that it
gives to a sick employee is 75% of the latter's full compensation. What it would be required to pay
under Section 14(a) of the Social Security Act would be merely 30% of a maximum of 60% of the
daily rate of compensation, or 18% of the daily wage. This is so, because under paragraph (b) of
Section 14, the employer is entitled to the reimbursement by the System of 70% per centum of the
daily benefits granted the employee under the law. Add this to the 75% payable under the private
plan and it would give a total of only 93% of the daily rate of wage of the employee.
Besides, the employer is not without any remedy. Section 9 of the Social Security Act gives the
employer and employee the right to agree on "any changes, adjustments, modifications,
eliminations or improvements in the benefits to be available under the remaining private plan,
which may be necessary to adopt by reason of the reduced contribution thereto as a result of the
integration" of the benefits under the Act and those under the private benefit plan enforced by the
Company.
Finding no reason to disturb the resolution of the Social Security Commission appealed from, the
same is hereby affirmed, with costs against the appellant. So ordered.
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