G.R. No. L-47953 July 20, 1982
LILIA B. GALCERAN, petitioner, vs. SECRETARY OF LABOR & THE HI-CEMENT CORPORATION, respondents.

FACTS

Noel Galceran, an employee of Hi-Cement Corporation, suffered severe head and neck injuries on May 17, 1970, when his head was caught in factory machinery during work. He was hospitalized and diagnosed with extensive avulsion of the scalp and neck and severe cerebral concussion. On August 5, 1970, Galceran committed suicide by hanging. His widow, Lilia Galceran, filed a claim for death compensation benefits in 1975.
The Acting Referee dismissed the claim, ruling suicide was not compensable. The Secretary of Labor affirmed the dismissal, denying the petitioner’s motion for reconsideration. The petitioner argued her husband’s suicide was an after-effect of the work-related accident, as the cranial injuries caused insanity that deprived him of normal judgment. She supported this with a medical opinion from Dr. Benvenuto T. Juatco, who concluded the brain injuries led to mental deterioration and the suicidal act was done during a moment of mental loss. The respondents countered there was no evidence of insanity and that the medical opinion was inadmissible as the doctor did not personally attend to the deceased.

ISSUE

Whether the death of Noel Galceran by suicide is compensable under the Workmen’s Compensation Act.

RULING

Yes, the death is compensable. The Court reversed the orders of dismissal. Under Section 2 of the Workmen’s Compensation Act, compensation is due for injuries arising out of and in the course of employment. While Section 4 excludes injuries caused by the employee’s “voluntary intent,” this exclusion does not apply when a work-connected injury precipitates a mental derangement that directly causes the suicide. In such cases, the self-inflicted injury is not considered “voluntary” or “willful” within the meaning of the Act.
Applying this principle, the Court found that the severe cerebral concussion and related brain injuries sustained in the accident could have resulted in mental disturbance, as indicated by the medical opinion. Given the statutory presumption of compensability and the constitutional mandate for social justice, requiring a liberal interpretation in favor of labor, the suicide was deemed a direct consequence of the work-related injury. The claimant was not afforded a hearing to fully establish the medical link, but the evidence on record sufficed to warrant compensation. The employer was thus ordered to pay death benefits, burial expenses, attorney’s fees, and administrative fees to the petitioner.