G.R. No. L-31284 June 11, 1975
SEVEN-UP BOTTLING COMPANY, INC., ILOILO, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and HENRIETTA VDA. DE PENAFLORIDA for herself and in behalf of her minor child WILLENETTE PENAFLORIDA, respondents.

FACTS

On October 2, 1962, stock clerk William Peñaflorida died from a hand grenade explosion inside the office of the Seven-Up Bottling Company in Iloilo City. The company filed an employer’s report indicating its intent to controvert the subsequent compensation claim filed by the deceased’s widow, Henrietta Vda. de Peñaflorida. The Acting Referee initially dismissed the claim, finding the death did not arise out of and in the course of employment. The Referee relied on testimony from company witness Victorino Trespeces and a police report, which indicated Peñaflorida was intoxicated and had himself threatened to explode the grenade during a loan altercation with a co-worker.
The claimants moved to reopen the case to present Dr. Teodoro Centeno, the medico-legal officer who autopsied the body. Upon eventually testifying, Dr. Centeno stated he found no trace of liquor in the deceased’s body and suggested the grenade “could have been thrown from somewhere.” The Workmen’s Compensation Commission, giving greater weight to this medical testimony over the police report and Trespeces’s account, reversed the Referee. The Commission held the death compensable, applying the maxim falsus in uno, falsus in omnibus to discredit Trespeces’s entire testimony due to the alleged falsehood regarding intoxication.

ISSUE

Whether the death of William Peñaflorida arose out of and in the course of his employment, making it compensable under the Workmen’s Compensation Act.

RULING

No. The Supreme Court reversed the Commission’s decision and reinstated the dismissal of the claim. The Court found the Commission’s reliance on Dr. Centeno’s testimony was misplaced and that such evidence failed to constitute substantial proof to overturn the initial finding of non-compensability. Regarding intoxication, Dr. Centeno’s method—checking for an alcoholic odor in the breath of a corpse—was deemed inherently unreliable for detecting the presence of alcohol, especially absent a chemical analysis of stomach contents. His testimony was therefore insufficient to contradict the positive testimony of Trespeces and the police report.
Concerning the origin of the explosion, Dr. Centeno’s statement that the grenade “could have been thrown from somewhere” was explicitly characterized by the Court as mere conjecture and possibility without logical basis, as the witness himself admitted on cross-examination. This speculative testimony could not outweigh the direct evidence presented by the employer. Consequently, the claimants failed to discharge their burden of proving that the accident arose out of the employment. The fatal incident, occurring from a personal altercation involving a weapon unrelated to the soft drink business, lacked the requisite causal connection to Peñaflorida’s duties as a stock clerk.