Facts:

This case involves Elena Amedo, the plaintiff and appellant, against Rio y Olabarrieta, Inc., the defendant and appellee. The proceedings commenced on October 18, 1950, when Amedo sought to recover P2,038.40 as compensation for the death of her son, Filomeno Managuit, who was employed as a seaman aboard the M/S Pilar II. The tragic incident occurred on May 27, 1949, at approximately 11:30 AM, when Managuit jumped into the water to retrieve a 2-peso bill that had been blown overboard. As a consequence of this reckless act, Managuit drowned. Following Amedo's original claim, the defendant filed a motion to dismiss on the grounds that the plaintiff’s allegations did not establish that her son's death was due to an "accident arising out of and in the course of employment." The lower court granted the motion and dismissed the complaint on December 11, 1950. A subsequent appeal led to an affirmation of the dismissal by the Supreme Court on October 30, 1952, but allow

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Facts:

Background of the Case

• Plaintiff: Elena Amedo, mother of the deceased seaman, Filomeno Managuit.
• Defendant: Rio y Olabarrieta, Inc., employer of the deceased.
• Basis of Claim: Plaintiff sought compensation amounting to P2,038.40 for the death of her son.

Details of the Incident

• Date and Time: May 27, 1949, at approximately 11:30 in the morning.
• Location: Aboard the M/S Pilar II, anchored about 1½ miles from the seashore of Arceli Dumarang, Palawan.
• Incident Description:
• Filomeno Managuit, while performing his duties as an ordinary seaman, had his 2-peso bill blown away by the breeze.
• In his effort to retrieve the bill, he voluntarily jumped into the sea.
• As a consequence, he was drowned.

Procedural History

• Initial Action:
• October 18, 1950 – Plaintiff instituted the case by filing the original complaint.
• The complaint alleged that the death occurred while Filomeno was “on board” and engaged in work-related activities.
• Defendant’s Motion and Trial Court’s Dismissal:
• November 1, 1950 – Defendant filed a motion to dismiss, contending that the allegations did not establish an "accident arising out of and in the course of employment."
• December 11, 1950 – The trial court granted the motion and dismissed the complaint.
• A motion for reconsideration was filed and denied thereafter.
• Appeal and Amended Complaint:
• October 30, 1952 – The case went to the appellate court, which affirmed the dismissal but allowed the filing of an amended complaint within fifteen (15) days.
• December 22, 1952 – Plaintiff filed an amended complaint that reiterated the facts of the incident but maintained the claim under the Workmen’s Compensation Act.
• Final Trial Court Decision:
• The amended complaint was also dismissed upon a similar motion to dismiss, this time on the ground of failure to state a valid cause of action.

Statutory Framework and Relevant Provisions

• Act Nos. and Amendments Involved:
• The claim is based on Act No. 3428 (Workmen’s Compensation Act).
• Subsequent amendments by Act No. 3812 and Commonwealth Act No. 210 are considered.
• Republic Act 772, which took effect after the accident (June 20, 1952), is disregarded in the analysis.
• Key Provisions of Act No. 3428 (prior to its latest amendment):
• Section 2: States that compensation is granted when an employee sustains a personal injury “from any accident arising out of and in the course of the employment.”
• Section 4: Lists injuries not covered, specifically excluding injuries caused by the employee’s “voluntary intent, drunkenness, or notorious (gross) negligence.”

Contested Elements in the Incident

• “Arising Out of” Employment:
• The accident must have its origin or cause in the employment itself.
• Although the loss of the 2-peso bill may be seen as incidental to his work as a seaman, it did not constitute the direct cause of his death.
• “In the Course of” Employment:
• The casualty occurred at the time and place where the employment duties were performed.
• Employee’s Conduct:
• By voluntarily jumping into the sea to recover his bill, Filomeno deviated from the inherent risks of his employment.
• His act is scrutinized under the concept of “notorious negligence,” akin to “gross negligence.”

Issue:

Applicability of the Workmen’s Compensation Act to the Incident

• Whether the death of Filomeno Managuit resulted from an accident that “arose out of” his employment.
• Whether the accident occurred “in the course of” his employment.

Determination of the Causal Link Between Employment and the Accident

• Whether the risk of the lost 2-peso bill was inherently part of the duties of a seaman.
• Whether the act of voluntarily leaping into the sea to retrieve the bill breaks the necessary causal chain required for compensation.

Evaluation of Employee Negligence

• Whether the incident should be classified as resulting from “notorious negligence” (gross negligence).
• Comparison of the present case with previous cases involving similar circumstances of gross negligence and accidents.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)