SALVADOR LAZO v. EMPLOYEES COMPENSATION COMMISSION

FACTS:

Salvador Lazo, a security guard of the Central Bank of the Philippines, worked from 2:00 PM to 10:00 PM on June 18, 1986. Due to a security guard who failed to relieve him, Lazo had to render overtime duty until 5:00 AM the following day. After work, Lazo asked his superior for permission to leave early so he could bring home a sack of rice to Binangonan, Rizal. While on his way home at around 6:00 AM, the jeepney he was riding on turned turtle due to slippery roads, resulting in injuries. He was taken to the Angono Emergency Hospital and later transferred to the National Orthopedic Hospital, where he was confined until July 25, 1986. Lazo filed a claim for disability benefits under PD 626, but it was denied by the Government Service Insurance System (GSIS) on the grounds that he was not at his workplace when the accident occurred. The respondent Employees Compensation Commission affirmed the denial, stating that the accident happened far from Lazo's workplace, and he was attending to a personal matter at the time. Lazo appealed, arguing that his injuries should be compensable as they "arise out of or in the course of employment." He cited the case of Pedro Baldebrin vs. Workmen's Compensation Commission, where compensation was awarded to a petitioner who figured in an accident on his way home from his official station. The respondents claimed that the Baldebrin ruling deviates from earlier cases and does not apply to Lazo's situation.

ISSUES:

  1. Whether the injuries sustained by the petitioner on his way home from work are compensable under the Employees Compensation Law.

  2. Whether the Baldebrin ruling should be applied to the present case.

RULING:

  1. Yes, the injuries sustained by the petitioner on his way home from work are compensable under the Employees Compensation Law. The Court held that when an employee is accidentally injured at a point reasonably proximate to the place of work, while going to and from work, such injury is deemed to have arisen out of and in the course of employment. This is in line with the compassionate spirit of the employees compensation law as a social legislation.

  2. Yes, the Baldebrin ruling should be applied to the present case. The Court held that the ruling in Baldebrin, which awarded compensation to an employee who figured in an accident on his way home from his official station, is applicable and not a deviation from earlier decided cases.

PRINCIPLES:

  • Injuries sustained by an employee on the way to and from work are compensable under the Employees Compensation Law.

  • The employees compensation law should be interpreted liberally to give effect to its compassionate spirit as a social legislation.