Lasheras, Marry Rose S.
20140118985
G.R. No. 78617 June 18, 1990
SALVADOR LAZO vs. EMPLOYEES' COMPENSATION COMMISSION & GOVERNMENT
SERVICE INSURANCE SYSTEM (CENTRAL BANK OF THE PHILIPPINES)
FACTS:
The petitioner, Salvador Lazo, is a security guard of the Central Bank of the Philippines
assigned to its main office in Malate, Manila. His regular tour of duty is from 2:00 o'clock
in the afternoon to 10:00 o'clock in the evening. On 18 June 1986, the petitioner
rendered duty from 2:00 o'clock in the afternoon to 10:00 o'clock in the evening. But, as
the security guard who was to relieve him failed to arrive, the petitioner rendered
overtime duty up to 5:00 o'clock in the morning of 19 June 1986, when he asked
permission from his superior to leave early in order to take home to Binangonan, Rizal,
his sack of rice. On his way home, at about 6:00 o'clock in the morning of 19 June 1986,
the passenger jeepney the petitioner was riding on turned turtle due to slippery road.
As a result, he sustained injuries and was taken to the Angono Emergency Hospital for
treatment. He was later transferred to the National Orthopedic Hospital where he was
confined until 25 July 1986. For the injuries he sustained, petitioner filed a claim for
disability benefits under PD 626, as amended. His claim, however, was denied by the
GSIS for the reason that he was not at his work place performing his duties when the
incident occurred. It was held that the condition for compensability had not been
satisfied. Upon review of the case, the respondent Employees Compensation
Commission affirmed the decision since the accident which involved the petitioner
occurred far from his work place and while he was attending to a personal matter.
ISSUE:
Whether or not the injuries that petitioner sustained due to the vehicular accident on
his way home from work should be construed as "arising out of or in the course of
employment" and thus, compensable
LAW APPLICABLE:
P.D. No. 626 - otherwise known as the Employees Compensation Act., is a species of
social legislation, the primary purpose of which is to provide meaningful protection to
the ordinary worker against the perils of disability, the hazards of illness, and hardships
of other contingencies which may result in the loss of income. Indeed, it is the policy of
the State to give maximum aid and protection to labor.
CASE HISTORY:
This is an appeal from the decision of the respondent Employees Compensation
Commission (ECC) in ECC Case No. 2883 which affirmed the dismissal of petitioner's
claim for compensation against the Government Service Insurance System (GSIS).
RULING:
The Court has carefully considered the petition and the arguments of the parties and
finds that the petitioner's submission is meritorious. Liberally interpreting the Employee
Compensation Law to give effect to its compassionate spirit as a social legislation.
In Vano vs. GSIS & ECC, this Court, applying the above quoted decisions, enunciated:
Filomeno Vano was a letter carrier of the Bureau of Posts in Tagbilaran City. On
July 31, 1983, a Sunday, at around 3:30 p.m. Vano was driving his motorcycle
with his son as backrider allegedly on his way to his station in Tagbilaran for his
work the following day, Monday. As they were approaching Hinawanan Bridge in
Loay, Bohol, the motorcycle skidded, causing its passengers to be thrown
overboard. Vano's head hit the bridge's railing which rendered him unconscious.
He was taken to the Engelwood Hospital where he was declared dead on arrival
due to severe hemorrhage.
We see no reason to deviate from the foregoing ruling. Like the deceased in this
aforementioned case, it was established that petitioner's husband in the case at bar was
on his way to his place of work when he met the accident. His death, therefore, is
compensable under the law as an employment accident.
If the Vano ruling awarded compensation to an employee who was on his way from
home to his work station one day before an official working day, there is no reason to
deny compensation for accidental injury occurring while he is on his way home one hour
after he had left his work station.
We are constrained not to consider the defense of the street peril doctrine and instead
interpret the law liberally in favor of the employee because the Employees
Compensation Act, like the Workmen's Compensation Act, is basically a social legislation
designed to afford relief to the working men and women in our society.
OPINION:
I concur with the decision of the court specially when the court ruled that “this kind of
interpretation gives meaning and substance to the compassionate spirit of the law as
embodied in Article 4 of the New Labor Code which states that 'all doubts in the
implementation and interpretation of the provisions of the Labor Code including its
implementing rules and regulations shall be resolved in favor of labor. The policy then is
to extend the applicability of the decree (PD 626) to as many employees who can avail
of the benefits thereunder. This is in consonance with the avowed policy of the State to
give maximum aid and protection to labor. There is no reason, in principle, why
employees should not be protected for a reasonable period of time prior to or after
working hours and for a reasonable distance before reaching or after leaving the
employer's premises.”
Thus, shows that our labor laws are really compassionate towards the working force of
the Philippines, that it give guarantees toward the safety and benefits that they may
claim in case of disability, illness or other contingencies.
