GR L 14427; (August, 1960) (Digest)
G.R. No. L-14427; August 29, 1960
BATANGAS TRANSPORTATION COMPANY, petitioner, vs. GALICANO A. RIVERA and THE WORKMEN’S COMPENSATION COMMISSION, respondents.
FACTS
The Batangas Transportation Company (petitioner) appeals from the decision of the Workmen’s Compensation Commission holding it liable for compensation to its employee, Galicano Rivera, for the loss of his left leg due to a work-related accident. The Commission found that on March 13, 1956, Rivera was driving the petitioner’s bus from Batangas to Anilao at a moderate speed of about 20 km per hour. A jeepney ahead suddenly stopped without warning, and to avoid a collision, Rivera applied the brakes and swerved left, causing the bus to fall into a canal and overturn. The Commission discredited the testimonies of petitioner’s witnesses, Felipe Bautista (the bus conductor) and Felisa Buenviaje, who claimed Rivera was overspeeding and attempting to overtake at a sharp curve. The petitioner contests the Commission’s findings, arguing that Rivera’s injury did not arise out of his employment, was due to his own “notorious negligence,” and that the Commission’s conclusions lack evidentiary support.
ISSUE
Whether the Workmen’s Compensation Commission committed grave abuse of discretion or error in holding the petitioner liable for compensation, based on its factual findings that Rivera’s injury arose out of and in the course of his employment and was not due to his own notorious negligence.
RULING
The Supreme Court affirmed the Commission’s decision. The Court held that factual findings of the Workmen’s Compensation Commission are generally final and conclusive, unless there is grave abuse of discretion, or the findings are unsupported by substantial evidence. Here, the Commission’s findings were supported by evidence, including Rivera’s testimony and the improbability of high-speed travel on a bumpy road. The Court deferred to the Commission’s assessment of witness credibility, noting inconsistencies in Buenviaje’s affidavits and potential bias in Bautista’s testimony. Since Rivera was injured while performing his duty as a driver, the injury arose “out of and in the course” of employment and was compensable. The petitioner failed to prove “notorious negligence” by substantial evidence. Thus, no grounds existed to reverse the Commission’s decision. Costs were imposed on the petitioner.