GR 47044; (August, 1978) (Digest)
G.R. No. L-47044. August 22, 1978.
LUZVIMINDA Z. JAMER, petitioner, vs. REPUBLIC OF THE PHILIPPINES (Bureau of Public Schools) and THE SECRETARY OF LABOR, respondents.
FACTS
Petitioner Luzviminda Z. Jamer, a public school teacher at Bombon Elementary School in Camarines Sur, sustained injuries in a vehicular accident on September 12, 1973. The accident occurred while she was on a bus returning to her school after accomplishing a special errand for her school principal in Naga City. She filed a claim for compensation under the Workmen’s Compensation Act. The Referee of the Workmen’s Compensation Unit awarded compensation, finding the claim compensable as she was on an official errand and that the respondent’s controversion was pro-forma.
The respondent Bureau of Public Schools appealed to the Workmen’s Compensation Commission, which reversed the award. The Commission dismissed the claim, applying the general rule that accidents occurring off the employer’s premises while going to or from work are not compensable. The petitioner’s motion for reconsideration was subsequently denied by the Secretary of Labor, prompting this petition for review.
ISSUE
Whether the petitioner’s injuries sustained during a vehicular accident while on a special errand for her principal are compensable under the Workmen’s Compensation Act.
RULING
Yes, the claim is compensable. The Supreme Court reversed the decision of the Workmen’s Compensation Commission and reinstated the Referee’s award. The legal logic hinges on the application of exceptions to the “going to and coming from” rule. The general principle is that injuries sustained while commuting to or from work are not deemed to arise out of and in the course of employment. However, established jurisprudence recognizes exceptions when the employee is performing a special task or errand for the employer.
In this case, it was uncontroverted that the petitioner was on a special errand for her school principal at the time of the accident. This fact, supported by an affidavit from the principal, placed her journey within the scope of her employment duties. The Court emphasized that strict rules of evidence do not apply in workmen’s compensation proceedings, and such affidavits are admissible. By undertaking the errand at the principal’s behest, her travel became an integral part of her employment, removing it from the ordinary commute covered by the general rule. Consequently, the accident arose out of and in the course of her employment, making the resulting injuries compensable. The Court affirmed the computed award for disability compensation and medical reimbursement.