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CELERINO VALERIANO v. EMPLOYEES' COMPENSATION COMMISSION

FACTS:

Celerino Valeriano, a fire truck driver assigned at the San Juan Fire Station, was standing along Santolan Road in Quezon City when he met a friend, Alexander Agawin. They decided to go to Bonanza Restaurant for dinner and on their way home, the owner-type jeepney they were riding collided with another vehicle at the intersection of N. Domingo and Broadway streets in Quezon City. Valeriano was thrown out of the vehicle and sustained severe injuries. He filed a claim for income benefits under PD 626 with the Government Security Insurance Service, but his claim was denied on the ground that the injuries did not directly arise or result from the nature of his work. Valeriano appealed to the Employees' Compensation Commission (ECC), which ruled against him, stating that the accident occurred outside his time and place of work and he was not performing his official duties as a fireman at the time of the accident. The decision of the ECC was affirmed by the Court of Appeals, which agreed that petitioner's injuries were not work-connected.

ISSUES:

  1. Whether the injuries and resulting disability sustained by the petitioner were work-connected.

  2. Whether the cases of Hinoguin and Nitura are applicable to the petitioner's case.

  3. Whether the death of SPO2 Alegre is compensable under the Employee's Compensation Commission (ECC) guidelines.

  4. Whether the 24-hour-duty doctrine should be applied to the death of SPO2 Alegre.

RULING:

  1. The injuries and resulting disability sustained by the petitioner were not work-connected. The court held that for an injury and resulting disability to be compensable, they must have necessarily resulted from an accident arising out of and in the course of employment. The petitioner failed to demonstrate how his job as a firetruck driver was related to the injuries he had suffered. His injuries were not acquired at his work place, nor were they sustained while he was performing an act within the scope of his employment or in pursuit of an order of his superior. Therefore, his injuries and consequent disability were not compensable.

  2. The cases of Hinoguin and Nitura are not applicable to the petitioner's case. The court held that the concept of "work place" cannot always be literally applied to a soldier on active duty status who is subject to military discipline and law, and at the beck and call of his superior officers at all times. However, in the cases of Hinoguin and Nitura, there was a reasonable nexus between the absence of the deceased from their assigned place of work and the incidents causing their deaths. In the petitioner's case, there was no similar connection between his absence from his work place and the accidents he experienced. Therefore, the cases of Hinoguin and Nitura are not applicable.

  3. The death of SPO2 Alegre is not compensable under the ECC guidelines. The Court held that for a claim to be eligible for death benefits, the employee must be at the place where his work requires him to be, performing his official functions, or executing an order for the employer. In this case, SPO2 Alegre was not at his assigned work place, nor was he performing any act within his duty and authority as a policeman at the time of his death. Therefore, his presence at the scene of the crime, where he was shot while bringing his son to the police station, cannot be considered as work-related.

  4. The 24-hour-duty doctrine should not be sweepingly applied to all acts and circumstances causing the death of a police officer. It should only apply to acts that can be categorized as police service in character. In the absence of a prior directive or permission from a superior officer, or the peace-keeping nature of the act attended to by the police officer, the 24-hour-duty doctrine should not be invoked.

PRINCIPLES:

  • For an injury and resulting disability to be compensable, they must have necessarily resulted from an accident arising out of and in the course of employment.

  • The standard of "work connection" must be substantially satisfied for an injury to be compensable.

  • An injury or accident arises "in the course of employment" when it takes place within the period of employment, at a place where the employee may reasonably be, and while he is fulfilling his duties or is engaged in doing something incidental thereto.

  • The concept of "work place" cannot always be literally applied to a soldier on active duty status who is subject to military discipline and law, and at the beck and call of his superior officers at all times.

  • In cases involving soldiers or policemen, death benefits may be granted not just because they are virtually working round the clock, but because there is a reasonable nexus between the absence of the deceased from their assigned place of work and the incidents causing their deaths.

  • For a claim to be eligible for death benefits, the employee must be at the place where his work requires him to be, performing his official functions, or executing an order for the employer.

  • The 24-hour-duty doctrine applies to acts and circumstances causing the death of a police officer that can be categorized as police service in character. It should not be applied to acts that are intrinsically private and unofficial in nature.

  • The 24-hour-duty doctrine serves as an after-the-fact validation of acts to place them within the scope of ECC guidelines, and not as a blanket license to benefit police officers in all situations that may give rise to their deaths.