G.R. No. 84307 . April 17, 1989.
Ciriaco Hinoguin, petitioner, vs. Employees’ Compensation Commission and Government Service Insurance System (Armed Forces of the Philippines), respondents.

FACTS

Sgt. Lemick G. Hinoguin, a member of the Philippine Army, was the Detachment Non-Commissioned Officer stationed in Carranglan, Nueva Ecija. On August 1, 1985, he and two companions sought and obtained oral permission from their commanding officer to go on an overnight pass to Aritao, Nueva Vizcaya, to settle an important matter. They were authorized to carry their issued firearms because Aritao was considered a “critical place” due to peace and order problems. After arriving in Aritao and having lunch at a companion’s home, they consumed some alcohol. Later that evening, while boarding a tricycle for their return, one of the soldiers, Dft. Nicomedes Alibuyog, accidentally discharged his M-16 rifle, hitting Sgt. Hinoguin. Hinoguin was hospitalized and died on August 7, 1985, from complications of the gunshot wound. A military Line of Duty Board subsequently declared his death to be “in line of duty.”
Petitioner Ciriaco Hinoguin, the soldier’s father, filed a claim for death benefits under the Employees’ Compensation Act (P.D. No. 626, as amended). The Government Service Insurance System (GSIS) denied the claim, ruling that Sgt. Hinoguin was not at his place of work nor performing official functions at the time of the incident, as he was on a pass and coming from a social gathering. The Employees’ Compensation Commission (ECC) affirmed the denial.

ISSUE

Whether the death of Sgt. Lemick G. Hinoguin arose out of and in the course of his employment, making it compensable under the law.

RULING

Yes. The Supreme Court reversed the decisions of the GSIS and ECC, granting the claim for compensation benefits. The Court held that the death was compensable as it arose out of and in the course of employment. The legal logic centered on the unique nature of military service. The Court reasoned that a soldier, unlike a civilian employee, is considered to be on active duty status at all times, subject to military discipline and rules. The permission to go to Aritao did not constitute a break from this status, especially since they were ordered to carry their firearms due to the area’s critical peace and order situation. Thus, they were deemed to be performing a duty incidental to their military service.
Crucially, the Court found that the risk involved was inherent to the soldier’s employment. The hazard of being accidentally shot by a fellow soldier, given the constant presence and handling of firearms inherent in military life, is a risk a soldier is compelled to accept by the very nature of the profession. Therefore, the accidental shooting, which occurred while the soldiers were in the process of returning from an authorized trip with their service weapons, was directly connected to the conditions and obligations of military employment. The Court emphasized that the beneficent and humanitarian purposes of the labor laws warrant a liberal interpretation in favor of the employee, especially for members of the Armed Forces who face unique and constant hazards. The GSIS was directed to award all applicable benefits.