Title
Alano vs. Employees' Compensation Commission
Case
G.R. No. L-48594
Decision Date
Mar 16, 1988
A government employee died in a pre-work commute accident; SC ruled it compensable, emphasizing liberal interpretation favoring employees in death benefit claims.
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Case Digest (G.R. No. L-48594)

Facts:

  1. Employment Details:

    • Dedicacion de Vera was a government employee who worked as the principal of Salinap Community School in San Carlos City, Pangasinan.
    • Her regular working hours were from 7:30 a.m. to 5:30 p.m.
  2. Incident Leading to Death:

    • On November 29, 1976, at around 7:00 a.m., while waiting for a ride at Plaza Jaycee in San Carlos City on her way to school, she was hit and run over by a speeding Toyota mini-bus.
    • The accident resulted in her instantaneous death.
  3. Claim for Compensation:

    • On June 27, 1977, Generoso C. Alano, the brother of the deceased, filed a claim for income benefit with the Government Service Insurance System (GSIS) on behalf of the deceased's children.
    • The GSIS denied the claim, stating that the injury did not qualify as an employment accident under the law.
    • A request for reconsideration was also denied, and the case was elevated to the Employees' Compensation Commission (ECC).
  4. ECC Decision:

    • The ECC affirmed the GSIS decision, citing Section I(a), Rule III of the Amended Rules on Employees' Compensation, which requires that:
      (1) The injury must occur during working hours;
      (2) The injury must occur at the place where the employee's work requires them to be; and
      (3) The employee must be performing official functions.
    • The ECC ruled that the accident did not meet any of these conditions, as it occurred before working hours, at a location not considered her workplace, and while she was not performing official functions.

Issue:

  1. Whether the injury sustained by Dedicacion de Vera, resulting in her death, is compensable under the law as an employment accident.
  2. Whether the accident can be considered to have "arisen out of or in the course of her employment."

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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