GR L 30854; (November, 1982) (Digest)
G.R. No. L-30854 November 19, 1982
PHILIPPINE NATIONAL RAILWAYS, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and MARCELA VDA. DE YAMBOT, respondents.
FACTS
Moises Yambot, a telegraph operator for the Philippine National Railways, died from multiple stab wounds on May 10, 1963. At the time of his death, he was on vacation leave and was waiting at a public railroad station in San Miguel, Bulacan. The assailant, Inocencio Castillo, was the same individual who had approached Yambot at his workplace three days earlier, on May 7, 1963, while Yambot was on duty receiving telegrams.
During the May 7 incident, Yambot, busy with his work, told Castillo not to disturb him. Castillo retorted with a threat, warning Yambot “may araw ka rin sa akin.” The Acting Referee dismissed the subsequent claim for death benefits filed by Yambot’s widow, ruling the killing was due to personal causes occurring off-duty and unrelated to his work.
ISSUE
Whether the death of Moises Yambot arose out of and in the course of his employment, making it compensable under the Workmen’s Compensation Act.
RULING
Yes, the death is compensable. The Supreme Court affirmed the Workmen’s Compensation Commission’s award. The legal logic hinges on establishing a causal connection between the employment and the injury. The Court found that the fatal assault on May 10 was the direct consequence of the altercation that occurred at Yambot’s workplace on May 7.
The altercation itself arose out of the employment because Yambot’s rebuke to Castillo was made in the performance of his duty—he was attending to his work and preventing an interruption. The threat made by Castillo at that time materialized in the killing. The fact that the actual assault occurred while Yambot was on leave and at a different location does not sever this causal link. The risk of retaliation originated from an act done within the scope of his employment. Since the employer failed to rebut the evidence showing this work-connected origin, the death is deemed to have arisen out of and in the course of employment.