Case Summary (G.R. No. L-10675)
Case Background
This case stems from a fatal incident involving Dionisio Hio, who died while employed with the Compania Maritima. On the night of September 4, 1954, during a strike by the Marine Officer's Guild, Hio was assigned to provide security on the M/V BASILAN. Following an evening of drinking with others after his shift, he passed away under circumstances that prompted his widow to file for compensation from his employer, alleging he had died in the course of his employment.
Workmen's Compensation Commission's Findings
The Workmen's Compensation Commission determined that Hio's death resulted from an accident occurring in the course of his employment. Consequently, it ordered Compania Maritima to pay the survivors a death compensation of P4,000.00, reimbursement for burial expenses, and related fees under the Workmen's Compensation Act.
Employment Relationship
The petitioner contested the Commission's ruling, asserting that an employer-employee relationship did not exist between them and Dionisio Hio. However, the Commission found that even in the absence of a written contract, the funding for Hio's wages was directly sourced from Compania Maritima, indicating an employment relationship. The court rebutted the claim that Hio was merely a casual employee, emphasizing that his duties were integral to the company's operations.
Casual Employment Definition
The court clarified that under Section 39(b) of the Workmen's Compensation Act, "laborer" refers to a person employed by an employer, excluding those whose roles are purely casual and unrelated to the employer's business. The case law interpretation establishes that an employee's role must relate directly to the employer's primary business activities to not qualify as casual employment. Since Hio's security duties were closely aligned with the business operations of the petitioner, the court affirmed his status as an employee.
Issues of Intoxication
The petitioner further argued that Hio was intoxicated at the time of his death, which could exempt them from liability under the Workmen's Compensation Act. The Commission noted inconsistencies in witness testimonies regarding Hio's behavior after drinking with the Chief Engineer of the vessel. Notably, testimony from Hio's widow and the autopsy findings suggested he was not intoxicated, invoking legal precedents that state a lack of compelling evidence of intoxication would not absolve the employer from liability.
Burden of Proof on Intoxication
The ruling emphasized that any defense regarding intoxic
...continue readingCase Syllabus (G.R. No. L-10675)
Case Background
- The case involves an appeal by certiorari from a decision of the Workmen's Compensation Commission.
- The petitioner, Compania Maritima, is a domestic corporation established under Philippine laws for interisland trade.
- The respondent, Pablo Velez Watchmen's Agency, is a single proprietorship that provides watchmen and protective services to shipping companies.
- The watchmen are recruited from the Manila Bay Watchmen's Association, a registered labor organization with which Velez has a collective bargaining contract.
Incident Overview
- In August 1954, during a strike by the Marine Officer's Guild, Compania Maritima contracted Pablo Velez Watchmen's Agency for security services.
- Dionisio Hio, a watchman from the agency, was assigned as a gangwayman on the M/V BASILAN.
- On September 4, 1954, Hio was picked up by the Chief Engineer of the vessel and taken to his home, where they consumed several rounds of liquor.
- Hio and the other watchmen returned to their posts around 2:00 a.m. on September 5.
- Hio's body was discovered floating by the M/V BASILAN at approximately 6:00 a.m. on the same day.
Compensation Claim
- Ernesta Cabagnot Hio, the deceased's widow, filed a claim for compensation on behalf of herself and their three minor children.
- The Workmen's Compensation Commission ruled that Hio died from an accident occurring in the course of his employment.
- The Commission ordered Compani