G.R. No. L-18246; October 30, 1964
PEOPLE’S HOMESITE & HOUSING CORPORATION, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and ESTRELLA ALBA TITONG, respondents.

FACTS

Cesar Titong, employed as a checker by petitioner People’s Homesite & Housing Corporation, engaged in a heated argument and subsequent fistfight with a co-worker, Federico Magalang, on July 10, 1956, while both were on duty. During the altercation, Titong was struck, fell, and hit his head on a hollow block. He received emergency treatment but reported for work the following day. He continued working until July 17, 1956, when he complained of severe head pains. He was hospitalized and later died on August 25, 1956. A post-mortem examination determined the cause of death as “toxemia due to abscess of the brain and bed sore.” His widow, respondent Estrella Alba Titong, filed a claim for compensation under Act No. 3428 , as amended.
Petitioner contested the claim, asserting two primary defenses. First, it argued the injury and death did not arise out of and in the course of employment, contending the fight stemmed from a personal matter or a practical joke initiated by the deceased, amounting to his own notorious negligence. Second, it alleged the claim had prescribed due to the claimant’s failure to notify the employer of the injury within two months and to file the claim within three months after death, as required by Section 24 of the Workmen’s Compensation Act.

ISSUE

The core issues are: (1) Whether Titong’s death arose out of and in the course of his employment, making it compensable, and (2) Whether the claim for compensation had prescribed.

RULING

The Supreme Court affirmed the decision of the Workmen’s Compensation Commission, awarding compensation. On the first issue, the Court held the death was compensable. It reiterated the established doctrine that an injury arises “in the course of employment” when it occurs within the period of employment, at a place where the employee may reasonably be, and while he is fulfilling his duties or doing something incidental thereto. It was undisputed that Titong sustained the fatal injury within the employer’s premises during working hours while performing his duty as a checker. The Court found the circumstance that the fight may have been provoked by a joke or personal matter insufficient to constitute gross or notorious negligence that would bar compensation, citing the analogous case of La Mallorca Taxi vs. Guanlao. Furthermore, the Court invoked the legal presumption that a claim is compensable once death in the course of employment is proven, a presumption petitioner failed to rebut with substantial evidence.
On the second issue, the Court ruled the defense of prescription was waived. The Court found that the petitioner’s plant superintendent had knowledge of the accident on the very day it occurred, as evidenced by the Employer’s Report of Accident submitted by petitioner’s officials. Applying its precedent in Martha Lumber Mill, Inc. vs. Lagradante, the Court held that the employer’s failure to submit the required accident report within the statutory period constituted a waiver of the defense based on the claimant’s alleged late filing. Therefore, the claim was not barred by prescription.