Title
Government Service Insurance System vs. Court of Appeals
Case
G.R. No. 128524
Decision Date
Apr 20, 1999
Police officer's death while driving a tricycle for personal income deemed non-compensable; not work-connected under PD 626.
A

Case Digest (G.R. No. 128524)

Facts:

Government Service Insurance System (GSIS) v. The Honorable Court of Appeals and Felonila Alegre, G.R. No. 128524, April 20, 1999, Supreme Court Third Division, Romero, J., writing for the Court.

Private respondent Felonila Alegre claimed death benefits under Presidential Decree No. 626 after the December 6, 1994 fatal shooting of her husband, SPO2 Florencio A. Alegre, a police officer assigned to the Philippine National Police station in Vigan, Ilocos Sur. At the time of the shooting, SPO2 Alegre was driving a tricycle and ferrying passengers near the Imelda Commercial Complex, where SPO4 Alejandro Tenorio, Jr., Team/Desk Officer of the Police Assistance Center located at the complex, confronted him; a verbal altercation ensued and Alegre was fatally shot.

The widow filed a death benefits claim with petitioner GSIS, which denied the claim in a decision dated August 7, 1995, on the ground that SPO2 Alegre was engaged in a personal, non-work-connected activity when killed. The Employees’ Compensation Commission (ECC) affirmed GSIS’s denial in its May 9, 1996 decision. The Court of Appeals, however, reversed the ECC on February 28, 1997 (CA-G.R. SP No. 42003), holding that policemen are “technically on duty 24 hours a day” and that Alegre’s death occurred in the course of his work; the appellate court relied on Nitura v. Employees’ Compensation Commission and Employees’ Compensation Commission v. Court of Appeals in reasoning that a policeman’s “workplace” is not confined to a station.

Aggrieved, GSIS filed a petition for review on certiorari under Rule 45 of the Rules of Court to the Supreme Court, contesting the CA’s finding that Alegre’s death was work-connected and thus compensable under the ECC guidelines implementing P.D. No. 626.

Issues:

  • Was the death of SPO2 Florencio A. Alegre compensable under the Employees’ Compensation guidelines implementing P.D. No. 626 — i.e., was his death work-connected?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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