Case Digest (G.R. No. L-43792)
Facts:
The case involves Pedro O. Baldebrin, the petitioner, and the Workmen's Compensation Commission along with the Bureau of Lands as respondents. The incident leading to the case took place on April 21, 1970, when Baldebrin, who worked for the Bureau of Lands earning a monthly salary of P245.00, sustained an injury to his left eye while traveling home from his official station in Pagadian City to his residence in Aurora, Zamboanga del Sur. The accident occurred in Tukuran, Zamboanga del Sur when a pebble struck his eye while he was riding a bus. Following the accident, Baldebrin took multiple leaves of absence, totaling 128 days, to recover from the eye injury. Upon his return, it was determined through a medical evaluation by Dr. Romulo P. Montecillo that he had lost 50% of the vision in his left eye. The Workmen's Compensation Unit conducted an investigation but noted the absence of the Bureau of Lands at the hearing, resulting in no evidence contradicting Baldebrin's
... Case Digest (G.R. No. L-43792)
Facts:
- Petitioner: Pedro O. Baldebrin, employed as a “Computer” in the Bureau of Lands with a monthly salary of P245.00.
- Time and place details: Employed at the Bureau of Lands with his official station at Pagadian City and his residence at Aurora, Zamboanga del Sur.
Employment and Personal Background
- Date of incident: April 21, 1970 (a Friday).
- Circumstances: While returning home from Pagadian City by bus, petitioner's left eye was hit by a pebble in an accident that occurred in the municipality of Tukuran, Zamboanga del Sur.
- Nature of injury: The accident resulted in a severe eye injury, later medically evaluated.
The Accident
- Medical findings: On returning to work, the injury worsened with a medical evaluation by Dr. Romulo P. Montecillo (Medical Rating Officer) showing a loss of 50% use of the left eye.
- Absences: The injury caused petitioner to take several leaves of absence, totaling 128 days as recorded by the Workmen’s Compensation Unit.
- Evidence: Despite the absence of evidence contradicting petitioner’s account and the nonappearance of the Bureau of Lands in the investigation, these facts were corroborated by the Workmen’s Compensation Unit’s findings.
Post-Accident Developments
- Award Recommendation:
- The Workmen’s Compensation Unit recommended awarding petitioner a compensation benefit of P2,446.02 under Sections 14 and 17 of the Act.
- Attorney’s fees were to be granted in the amount of P122.30 under Section 31.
- A decision fee of P25.00 was also recommended under Section 55.
- Commission’s Decision: The respondent Workmen’s Compensation Commission, however, absolved the respondent Bureau of Lands from any liability by denying the award recommended by the unit.
- Petition for Review: Dissatisfied with the Commission’s ruling, petitioner appealed to the Court, asserting that his permanent partial disability resulting from the loss of vision in his left eye occurred in the course of his employment.
Proceedings in the Workmen’s Compensation Commission
- Similar Cases Cited:
- Philippine Engineer’s Syndicate, Inc. vs. Flora S. Martin and Workmen’s Compensation Commission: Held that accidents occurring outside strict working hours but connected to employment activities (such as boarding a service truck) can be compensable.
- Iloilo Dock & Engineering Co. vs. Workmen’s Compensation Commission: Expanded on the notion that employment includes the transit time to and from work if such transit is integral to employment.
- Statutory Principle: The pivotal issue involved the interpretation of the phrase “arising out of and in the course of employment” as stated in Section 2 of the Workmen’s Compensation Act, which is to be liberally construed in support of employees.
Contextual and Comparative Case References
Issue:
- Determination of the nexus between the accident and petitioner's employment duties.
- Evaluation of the accident’s occurrence (while in transit from work) as being sufficiently related to the employment.
Whether petitioner’s left eye injury, resulting in a permanent partial disability, falls within the ambit of “arising out of and in the course of employment” under the provisions of the Workmen’s Compensation Act.
- Consideration of whether absences and subsequent medical deterioration due to the accident substantiate compensability.
- Assessment of the absence of evidence from the Bureau of Lands and its impact on the liability determination.
Whether the incident, occurring during the employee’s journey from the official station to his residence, warrants the extension of employment benefits under the Act.
- Exploration of previous jurisprudence to ensure a liberal and purposive interpretation of the statutory language.
The appropriate legal construction of “employment” under social legislation designed to protect workmen.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)