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GOVERNMENT SERVICE INSURANCE SYSTEM v. JUM ANGEL

FACTS:

Sgt. Benjamin Angel, a soldier in the Philippine Army, was fetched from his post by Capt. Fabie Lamerez for an investigation on his alleged involvement in a pilferage/gunrunning case. He was placed in a detention cell and found dead the following day, with the cause of death determined as asphyxia by strangulation. Sgt. Angel's wife filed a complaint alleging murder and named the Intelligence Service Group led by Capt. Lamerez as suspects. The Office of the Provost Marshal found Sgt. Angel's death suspicious and recommended a court martial, while the Inspector General concluded that there was no evidence of foul play. Subsequently, the Judge Advocate General determined Sgt. Angel died in line of duty. The Philippine Army declared Sgt. Angel's death in line of duty, and his wife filed a claim for death benefits with the GSIS. The GSIS denied the claim, stating that Sgt. Angel's death did not arise out of and in the course of employment. The ECC also denied the claim, and the Court of Appeals reversed the decision, ordering the GSIS to pay the death benefits. The GSIS appealed the decision to the Supreme Court.

ISSUES:

  1. Whether the declaration by the Philippine Army that the death of Sgt. Angel was "in line of duty status" confers compensability under the provisions of Presidential Decree No. 626.

  2. Whether the proceedings before the Philippine Army can be used as a basis for the finding that the widow of Sgt. Angel is entitled to compensation under Presidential Decree No. 626, as amended.

  3. Whether the conflicting findings regarding Sgt. Angel's death, which include a recommendation from the Judge Advocate General and a declaration by the Chief of Staff of the Philippine Army, can be resolved in favor of the positive finding of no evidence of foul play.

  4. Whether compassion for the widow's predicament can tilt the balance in her favor despite the provisions of the law.

  5. Whether the Court of Appeals erred in its decision.

  6. Whether the Employees' Compensation Commission decision should be reinstated.

RULING:

  1. The Court ruled in favor of the petitioner GSIS.

  2. The proceedings before the Philippine Army which resulted in the declaration that Sgt. Angel's death was "in line of duty status" cannot be used as a basis for the widow's entitlement to compensation under Presidential Decree No. 626, as amended. Death in line of duty is different from a finding that the death resulted from an accident and was not occasioned by the sergeant's willful intention to kill himself.

  3. The conflicting findings regarding Sgt. Angel's death, which include one finding of no evidence of foul play and another finding that foul play may have been committed, are resolved in favor of the positive finding that there is no evidence of foul play. The circumstances of Sgt. Angel's death, with his lifeless body found hanging inside his cell with an electric cord tied around his neck, together with the unrebutted finding of no evidence of foul play, negate the widow's claim of murder and compensability of such death.

  4. Regardless of compassion for the widow's predicament, the balance between obligation and right in employee's compensation cases has been considered. The need to show greater concern for the trust fund and to avoid endangering its integrity outweighs the sympathy for the widow. The equilibrium between the employer's obligation to pay compensation and the employee's right to receive it must be maintained.

  5. The decision of the Court of Appeals is reversed.

  6. The Employees' Compensation Commission decision is reinstated.

PRINCIPLES:

  • For an injury and resulting disability or death to be compensable, it must be the result of an accident arising out of and in the course of employment.

  • An accident is an event that occurs by chance or fortuitously, without intention or design, and which is unexpected, unusual, and unforeseen.

  • An accident excludes acts that happen with intention or design, with one's foresight or expectation.

  • The State Insurance Fund shall not be liable for compensation if the disability or death was occasioned by the employee's intoxication, willful intention to injure or kill himself or another, notorious negligence, or otherwise provided under the law.

  • The finding of military authorities regarding an employee's death while in the line of duty is not binding on the Employees' Compensation Commission (ECC).

  • Proceedings before the Philippine Army cannot be used as basis for entitlement to compensation under Presidential Decree No. 626, as amended.

  • Death in line of duty is different from a finding that the death resulted from an accident and was not intentional.

  • Conflicting findings regarding the cause of death should be resolved in favor of the positive finding based on the evidence presented.

  • Compassion for the beneficiaries should be balanced with the need to protect the integrity of the trust fund and avoid endangering it.

  • The Court has the power to reverse the decision of the Court of Appeals.

  • The Employees' Compensation Commission decision can be reinstated if it is found to be in accordance with the law.