G.R. No. 90267 December 21, 1993
PERLITA LOPEZ, petitioner, vs. EMPLOYEES COMPENSATION COMMISSION, GOVERNMENT SERVICE INSURANCE SYSTEM, DEPARTMENT OF EDUCATION, CULTURE AND SPORTS, respondents.

FACTS

Petitioner Perlita Lopez filed a claim for death benefits under P.D. No. 626 following the death of her husband, Pedro Lopez, a public school teacher at Urdaneta National High School. On April 27, 1987, Pedro Lopez was officially designated by his school’s Science Department head, with the principal’s notation, to prepare a “MODEL DAM” as the school’s official entry for a Division Search for Outstanding Improvised Secondary Science Equipment for Teachers scheduled for October 8 and 9, 1987. He was advised to complete the project on or before the contest date. In compliance, Lopez constructed an improvised electric micro-dam at his home. On May 27, 1987, at around 6:30 A.M., while working on the project at home, he was electrocuted by a live wire and died. The death certificate indicated cardiac arrest due to accidental electrocution. The GSIS denied the claim, ruling the death did not arise out of and in the course of employment. The ECC affirmed the denial, citing that at the time of the accident, Lopez was supposed to report for duty to assist in student enrollment but opted to work on the project at home, thus failing to satisfy the conditions under the Amended Rules on Employees Compensation.

ISSUE

Whether or not the Employees Compensation Commission committed grave abuse of discretion in holding that the cause of death of petitioner’s husband is not work-connected and therefore not compensable under P.D. No. 626.

RULING

The Supreme Court GRANTED the petition, REVERSED the decision of the ECC, and ORDERED the GSIS to pay death benefits to petitioner. The Court held that the death of Pedro Lopez was service-connected and compensable. Although the accident occurred at his home and not at his official work station, he was discharging his official function by working on the school project he was ordered to complete within a specific deadline. The Court emphasized that the Employees Compensation Act is a social legislation to be liberally construed in favor of labor. It found that the conditions under the amended rules were satisfied: Lopez was at the place where his work required him to be, as implied permission or direction was given to work at home to meet the deadline, and he was executing an order from his superior. The fact that the accident happened during summer vacation did not negate the employer-employee relationship. The ECC’s denial was a grave abuse of discretion, ignoring the compassionate spirit of the law.