GR 43058; (October, 1977) (Digest)
G.R. No. L-43058 October 6, 1977
TERESITA GALINDEZ, in her own behalf and in behalf of her minor son JOSE GALINDEZ, JR., petitioners, vs. WORKMEN’S COMPENSATION COMMISSION and the UNIVERSITY OF MINDANAO, respondents.
FACTS
Jose Galindez, Sr., a college professor at the Tagum branch of the University of Mindanao, died in a bus accident in Carmen, Davao del Norte, on a Friday morning. His widow, Teresita Galindez, filed a claim for death compensation. The Regional Office issued an award in her favor, finding the death compensable as arising out of and in the course of employment, noting the employer’s failure to seasonably controvert the claim. The University of Mindanao moved for reconsideration, asserting it had filed a controversion. The Workmen’s Compensation Commission reversed the award, holding that the records did not show the deceased was on an official mission or furthering his duties at the time of the accident. It cited Iloilo Dock and Engineering Co. vs. WCC, stating that mere proof of an accident does not create a presumption of compensability without some evidence connecting it to the employment.
ISSUE
Whether the death of Jose Galindez, Sr. is compensable under the Workmen’s Compensation Act.
RULING
Yes, the death is compensable. The Supreme Court reversed the Commission’s decision. The legal logic proceeds from the nature of the Workmen’s Compensation Act as social legislation designed for the employee’s benefit. The Court distinguished the cited Iloilo Dock case, clarifying it applies to situations after a full hearing reveals no connection, not to cases like this decided on the pleadings under summary procedures. Crucially, the factual circumstances—his employment in Tagum, residence in Tagum, the main office in Davao City, the accident on a working day along the route between these points, the lack of any leave of absence, and the employer’s failure to disprove the claim he was attending a conference—collectively give rise to a disputable presumption that he was on an official mission. The employer presented no evidence to rebut this presumption. Furthermore, the employer’s failure to seasonably controvert the claim within the statutory period constituted a waiver of non-jurisdictional defenses, including the defense that the accident did not arise out of employment. Thus, the presumption of compensability under the Act stands unrebutted, mandating an award in favor of the claimants.