GR 89168; (May, 1991) (Digest)
G.R. No. 89168 ; May 14, 1991
Rosa Lentejas, petitioner, vs. Employees’ Compensation Commission, respondent.
FACTS
Victorio Lentejas, a general foreman at the City Engineer’s Office of Calbayog City, was assigned on July 25, 1984, to inspect construction work on a damaged seawall in Barangay Banti. His official working hours were from 8:00 A.M. to 5:00 P.M. At around 4:30 P.M., while reportedly on his way home from the inspection site, he was attacked and stabbed to death by Arnulfo Luaton. Police investigation established that the motive for the killing was a personal grudge arising from a boundary dispute over adjoining lots owned by Victorio and the assailant.
Petitioner Rosa Lentejas, Victorio’s surviving spouse, filed a claim for death benefits under Presidential Decree No. 626, as amended. The Government Service Insurance System (GSIS) denied the claim, ruling that the death was not work-connected because it was motivated by personal animosity. The Employees’ Compensation Commission (ECC) affirmed the GSIS denial. Petitioner elevated the case to the Supreme Court via a Petition for Review on Certiorari.
ISSUE
Whether the death of Victorio Lentejas, resulting from a personal grudge-motivated attack while he was returning from an official work assignment, is compensable under the employees’ compensation law.
RULING
Yes, the death is compensable. The Supreme Court reversed the ECC decision and granted the claim. The legal logic centers on the application of the “going to and from work” rule and the concept of “work-connection” under the Amended Rules on Employees’ Compensation.
The Court found that at the time of the attack, Victorio was on official time and in the course of performing his official functions, having just completed an inspection at a place his work required him to be. The killing occurred at 4:30 P.M., within his official hours, and the route he took was a usual one from the worksite. Following established jurisprudence (Vda. de Torbela, Alano, Vano, Lazo), an injury or death sustained by an employee while on a necessary route to or from the place of work, during work hours, is deemed to have arisen out of and in the course of employment.
The Court rejected the argument that the personal motive of the assailant severed the work-connection. It held that from the victim’s perspective, the criminal assault was as external and fortuitous an event as a vehicular accident in the cited comparable cases. The assailant’s criminal intent does not constitute a supervening cause that nullifies the established facts that the employee was at a place his work required him to be and was performing his official duties. The compensability is determined by the circumstances of the employee’s presence at the time and place of the accident, not by the third party’s motive. The case was remanded to the ECC and GSIS for proper disposition.
