Title
A. L. Ammen Transportation Co., Inc. vs. Workmen's Compensation Commission
Case
G.R. No. L-20219
Decision Date
Sep 28, 1964
Agripino Jacob, on leave, was killed at a labor union meeting. His widow's compensation claim was denied as his death did not arise from employment duties and was filed late. The company's appeal failed due to procedural errors.
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Case Digest (G.R. No. L-20219)

Facts:

  1. Employment and Incident:

    • Agripino Jacob was employed as a line inspector by A. L. Ammen Transportation Co., Inc., with a monthly salary of P165.00.
    • On October 11, 1960, at around 3:00 p.m., Jacob attended a meeting of the board of directors and officers of the Bicol Transportation Employees Mutual Aid Association (BITEMAA), an independent labor organization.
    • During the meeting, Jacob was attacked by a co-employee with a bolo, leading to his death on October 12, 1960.
  2. Claim and Employer's Defense:

    • Josefa Baluis Vda. de Jacob, the widow of Agripino Jacob, filed a claim for compensation with the regional office of the Department of Labor in Naga City on April 4, 1961.
    • The company opposed the claim, arguing that Jacob's death did not arise out of or in the course of his employment, as he was on a leave of absence at the time of the incident.
  3. Initial Decision and Appeal:

    • The hearing officer dismissed the complaint, agreeing with the company's defense.
    • The Workmen's Compensation Commission reversed this decision on July 3, 1962, declaring the claim compensable and ordering the company to pay P4,000.00 as compensation, P200.00 for funeral expenses, P300.00 as attorney's fees, and P46.00 as docket fees.
    • The company filed a petition for review with the Supreme Court.
  4. Stipulation of Facts:

    • Jacob was on a duly approved leave of absence when the incident occurred.
    • The purpose of the BITEMAA meeting was to discuss the lifting of the expulsion of one Simeon Vellez from its board of directors.
    • There was no evidence of any motive for the attack on Jacob.
  5. Commission's Reasoning:

    • The Commission found Jacob's death compensable, reasoning that his role as BITEMAA president promoted better employer-employee relations, which indirectly benefited the company.
  6. Prescription of Claim:

    • The claim was filed nearly five months after Jacob's death, contrary to Section 24 of Act 3428, which requires claims to be filed within three months.
  7. Procedural Issue:

    • The widow and the Workmen's Compensation Commission later argued that the company failed to perfect its appeal by not filing a notice of appeal with the Commission, as required by Rule 43 of the Rules of Court.

Issue:

  1. Whether Agripino Jacob's death arose out of or in the course of his employment, making it compensable under the Workmen's Compensation Act.
  2. Whether the claim for compensation was filed within the prescribed period.
  3. Whether the company properly perfected its appeal to the Supreme Court.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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