GR 24778; (October, 1971) (Digest)
G.R. No. L-24778 October 29, 1971
WILLIAM LINES, INC., petitioner, vs. CLARIZA MONDRAGON SAÑOPAL, and WORKMEN’S COMPENSATION COMMISSION, respondents.
FACTS
Salvador Sañopal, employed as a watchman by William Lines, Inc. on the M/V Kolambugan, died of coronary thrombosis on board the vessel while docked at Pier 6, Manila, on August 31, 1962. He complained of illness after his duty hours, was attended by the ship’s physician, but expired shortly thereafter. The employer arranged for funeral services and transported the body to Iloilo City at its own expense. The widow, Clariza Mondragon Sañopal, filed a claim for compensation benefits on May 10, 1963. The petitioner employer moved to dismiss the claim, arguing it was filed beyond the three-month prescriptive period and that the death did not arise out of or in the course of employment, as Sañopal was off-duty and his work as a watchman did not involve strenuous activity.
ISSUE
The principal issues are: (1) whether Sañopal’s death arose out of and in the course of his employment, and (2) whether the claim for compensation had prescribed.
RULING
The Supreme Court affirmed the Workmen’s Compensation Commission’s award. On the first issue, the Court upheld the Commission’s factual finding, based on credible testimony, that Sañopal had voluntarily assisted in loading cargo to expedite the vessel’s delayed departure before he was stricken. This act, though beyond his strict duties, was an exercise of ordinary discretion to promote the employer’s business. Applying the “personal doctrine,” the Court ruled that an injury occurring on the employer’s premises during an interval outside regular hours can still arise in the course of employment, as the employee remains subject to environmental hazards associated with the employment. Given the nature of his employment requiring him to stay on board, his death was compensable.
On the issue of prescription, the Court ruled that the claim was not barred. While Section 24 of the Workmen’s Compensation Act requires claims to be filed within three months after death, this requirement is dispensed with if the employer has voluntarily made compensation payments. The petitioner’s act of defraying the expenses for transporting the deceased’s body to Iloilo constituted a voluntary payment of burial expenses, which are part of death benefits under Section 8 of the Act. This voluntary payment interrupted the prescriptive period, making the widow’s claim timely filed.