G.R. No. 156182; April 13, 2007
GOVERNMENT SERVICE INSURANCE SYSTEM, Petitioner, vs. LUZVIMINDA C. MECAYER, Respondent.

FACTS

SPO2 Jose P. Mecayer, a member of the Philippine National Police, was shot and killed by a fellow officer, SPO1 Timoteo Bawar, on June 12, 1992, while on duty at Camp Crame. The incident occurred after Mecayer, who was in the process of consuming a bottle of beer, had a heated argument with the assailant’s wife. The Government Service Insurance System (GSIS) denied the widow’s claim for death benefits under PD 626, as amended, stating the death resulted from a personal grudge and was not work-related. The Employees’ Compensation Commission (ECC) affirmed the denial, ruling the death was not compensable because it was occasioned by Mecayer’s intoxication, a disqualifying condition under the rules.
The Court of Appeals reversed the ECC decision. It found no substantial evidence to prove Mecayer was in a state of intoxication at the time of the shooting. The CA noted that the ECC based its finding solely on the fact that Mecayer was drinking a bottle of beer, without proof that his mental faculties were impaired. The CA thus declared the widow entitled to compensation benefits, prompting GSIS to elevate the case to the Supreme Court.

ISSUE

Whether the death of SPO2 Jose P. Mecayer is compensable under the Employees’ Compensation Law despite the allegation that it was occasioned by his intoxication.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. For intoxication to bar compensation under PD 626, it must be the proximate cause of the death or injury. The burden of proving this lies with the party asserting it—in this case, the GSIS and ECC. The Court emphasized that intoxication is not merely the act of drinking but a condition where mental faculties are so impaired as to diminish capacity for work.
Here, the evidence was insufficient. The fact that Mecayer was drinking a bottle of beer does not, by itself, establish a state of intoxication that proximately caused his death. There was no showing he was drunk or that his condition led directly to the shooting. The altercation with the assailant’s wife and the subsequent shooting, while occurring during his tour of duty, were not proven to be a direct result of impairment from alcohol. Since the contingency arose in the course of employment and the disqualifying cause of intoxication was not substantiated, the claim is compensable. The Court reiterated the principle of liberality in construing compensation laws in favor of labor.