G.R. No. L-37896 July 22, 1981
LUZON STEVEDORING CORPORATION, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and LEONARDA VDA. DE HAYSON, respondents.

FACTS

Pantaleon Hayson, a Gang Boss (capataz) for Luzon Stevedoring Corporation, was on duty aboard the M/V President Aguinaldo on February 16, 1970. While waiting for cargo with co-workers, he asked a ship officer for a drink due to the cold night. The officer provided a half-filled bottle believed to contain Tanduay Rhum. Hayson took the first drink, after which his co-workers discovered the liquid was actually oil of wintergreen. Hayson later complained of stomach pain, was hospitalized, and died the next morning due to poisoning, as confirmed by autopsy.
The deceased’s widow, Leonarda Vda. de Hayson, filed a claim for death benefits under the Workmen’s Compensation Act. The WCC Referee awarded compensation, finding the death arose out of and in the course of employment. The Workmen’s Compensation Commission en banc affirmed the award. The employer, Luzon Stevedoring Corporation, appealed, contending the death resulted from Hayson’s notorious negligence in drinking the substance, thus barring compensation under Section 4 of the Act.

ISSUE

Whether the death of Pantaleon Hayson, resulting from accidental poisoning after drinking oil of wintergreen mistaken for liquor while on duty, is compensable under the Workmen’s Compensation Act, or is barred due to alleged notorious negligence.

RULING

The Supreme Court affirmed the WCC decision, holding the death compensable. The legal logic is twofold. First, the Court upheld the WCC’s finding that Hayson’s act did not constitute “notorious negligence,” defined as an entire want of care raising a presumption of conscious indifference to probable consequences, practically equivalent to an intentional wrong. The evidence showed Hayson mistakenly drank from a bottle he believed contained ordinary liquor; there was no proof he was aware of the danger or acted with reckless disregard for his safety. His act constituted, at most, simple negligence, which does not disqualify a claim.
Second, the death arose out of and in the course of employment, satisfying the conditions for compensability. Hayson was injured at his place of work, during his work period, while performing an act incidental to his employment. The act of seeking a drink to alleviate discomfort from the cold while waiting for work is considered reasonably necessary to an employee’s comfort and health, and thus incidental to employment. Furthermore, the Court emphasized the presumptive compensability of claims under the Workmen’s Compensation Act, a social legislation to be construed liberally in favor of labor. Any doubts must be resolved in favor of the employee’s dependents. The employer failed to rebut this presumption with substantial evidence.