G.R. No. L-14827 - Chua Yeng vs. Roma

Santos Romeo, an employee working as a cargador for petitioner Chua Yeng, was engaged in loading and unloading copra at the warehouse located on C. Padilla Street, Cebu City.
The incident arose on May 16, 1956, when the laborer, upon asking his employer’s permission, left the workplace to obtain a drinking water supply due to the inoperative water pump and inadequate water facilities at the warehouse.

Santos Romeo proceeded to the petitioner’s house situated just across the street from the warehouse to secure water for drinking.
While in the kitchen, he observed a puppy consuming fried fish stored in an open cabinet.
In an effort to drive the puppy away by making a hand motion, he was bitten on the right hand by the animal.
The bite later resulted in hydrophobia, and on June 26, 1958, Santos Romeo died as a consequence of the injury.

The location of the incident, though at the petitioner’s house instead of the usual workplace, was reached due to the employer’s fault—failure to provide adequate drinking water within or near the workplace.
It was noted that the deceased’s usual water supply came from a well located at the back of the warehouse, which was not operational at the time of the incident.
This forced Santos Romeo to travel across a public street, thereby exposing himself to additional hazards.

The act of attempting to drive away the puppy was deemed to be instinctive and a natural response considering the circumstances and his loyalty to his employer’s property.
Precedents indicate that incidental actions linked to satisfying a worker’s basic needs or protecting the employer’s property may be compensable under the Workmen’s Compensation Act.
Substantial evidence presented to the Workmen’s Compensation Commission supported the fact that the injury was connected to the employment and that the circumstances surrounding the incident were within the scope of the worker’s duties.

Whether the act of leaving the workplace to fetch drinking water could be squarely considered as "arising out of and in the course" of employment, even though it occurred at the petitioner’s house rather than within the warehouse premises.
Whether the resultant injury—sustained from a dog bite incurred while attempting to drive away a puppy—falls within the ambit of compensable acts under the Workmen’s Compensation Act.
The extent to which the employee’s act, which was influenced by an instinctive reaction and sense of loyalty to his employer, can be deemed a voluntary deviation from his regular duties.
Whether the employer’s neglect in providing adequate and proximate drinking water facilities contributed significantly to the hazard that ultimately led to the employee's fatal injury.