G.R. No. 78617, June 18, 1990
Salvador Lazo, petitioner, vs. Employees’ Compensation Commission & Government Service Insurance System (Central Bank of the Philippines), respondents.

FACTS

Petitioner Salvador Lazo, a security guard for the Central Bank, completed his regular duty from 2:00 PM to 10:00 PM on June 18, 1986. He then rendered overtime duty until 5:00 AM the following day due to the absence of his reliever. After obtaining permission to leave, he departed to bring home a sack of rice to Binangonan, Rizal. At approximately 6:00 AM on June 19, 1986, the passenger jeepney he was riding in met an accident due to a slippery road, causing him injuries that required hospitalization.
The GSIS denied his claim for disability benefits under PD 626, as amended, stating the accident did not occur at his workplace while he was performing his duties. The ECC affirmed this dismissal, ruling the accident happened while he was attending to a personal matter and was far from his place of employment.

ISSUE

Whether the injuries sustained by the petitioner from a vehicular accident while on his way home from work, including overtime, are compensable as arising out of or in the course of employment.

RULING

Yes. The Supreme Court reversed the ECC decision, ruling the claim is compensable. The legal logic rests on a liberal interpretation of the Employees’ Compensation Act as a social legislation, consistent with the constitutional policy to afford maximum aid and protection to labor. The Court rejected a rigid application of the “workplace” requirement, emphasizing that employees should be protected for a reasonable period and distance when going to or from work.
The Court found the petitioner’s situation analogous to precedents where compensation was awarded. In Vda. de Torbela v. ECC and Alano v. ECC, employees who died while on their way to work were granted benefits. Crucially, in Baldebrin v. Workmen’s Compensation Commission, compensation was awarded to an employee injured while on his way home from his official station. The Court held there is no valid distinction in principle between commuting to work and commuting from work for compensability purposes, especially when the journey follows immediately after a prolonged work shift.
The fact that the petitioner was attending to a personal errand (bringing home rice) did not negate compensability, as he was essentially on his ordinary route home after an extended work period. The ruling extends the “reasonable time and distance” doctrine to homeward commutes, ensuring the law’s compassionate spirit is served by covering accidents occurring within a reasonable period after leaving the work station. The case was remanded to the ECC and GSIS for proper disposition.