FACTS: Deceased was a driver mechanic of a

company engaged in an ILLEGAL TRADE, the

manufacture
of blasting caps. One day he dies because of a
dynamite explosion. Issue: Is his death compensable
under the Workmen’s Compensation Law?
HELD: Yes, even if the trade was illegal. After
all, it was his employers, not he, who were engaged
in
illegal trade. Moreover, the Workmen’s
Compensation
Law is a SOCIAL legislation.

FACTS: Alejandro Ras, after having acquired a four-

hectare
parcel of land from the National Abaca and Other
Fibers
Corporation (NAFCO), leased, before the expiration
of 10 years
from such acquisition, the land in favor of defendant
spouses
(Ramon and Estela Sua). In view of the failure of the
lessees to
comply with the terms of the lease contract (e.g.,
failure to pay
rentals), Ras sued for the rescission of the contract.
The lessees
contended, among other things, that the lessor Ras
had no right
to sue because of a violation of Rep. Act 477,
prohibiting the
alienation or encumbering of land acquired from the
NAFCO
within 10 years from the issuance of the
corresponding certifi -
cate of title. Issue: Considering the pari delicto
doctrine, may
Ras successfully sue for the recovery of the land?
HELD: Yes, Ras may still sue for the recovery of the
land.
RA 477 is silent as to the consequence of the
encumbering of the
land within the 10-year prohibited period. But
considering that
the aim of the government in allowing the
distribution or sale of
disposable public lands to deserving applicants is to
enable the
landless citizens to own land they can work on, and
considering
that the reversion of these lands to the government is
penal in
character, reversion cannot be construed to be
implied from the
provision prohibiting certain acts. Where, as in this
case, the
interest of the individual outweighs the interest of the
public, strict construction of a penal provision is
justifi ed under Art. 1416 of the Civil Code.