Belarmino v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Cirilo Belarmino, employed as a capataz by Pacific Metals Corporation, was shot and killed by Ponciano Angeles, a subordinate, between 5:00 to 5:20 PM on October 9, 1969, approximately 75 feet away from the employer's compound, after working hours which ended at 4:00 PM. The widow of the deceased filed a claim for death benefits. Procedural History: The claim was dismissed by the Acting Referee for lack of merit. The Workmen's Compensation Commission (WCC) en banc affirmed the dismissal, holding that while Pacific Metals Corporation was the employer, the accident was not work-connected as it occurred outside the premises and after working hours. The WCC cited the 'going and coming rule' and stated employers are not insurers against all accidents. The Petition: The petitioners, Encarnacion Belarmino and her minor children, sought a review of the WCC's dismissal, arguing the death was compensable.
Issue(s)
Whether the death of an employee caused by an assault from a co-employee after working hours and at some distance from the employer's premises is compensable under the Workmen's Compensation Act. Whether the Workmen's Compensation Commission committed a gross misappreciation of evidence in disregarding the widow's testimony regarding a misunderstanding between the deceased and the assailant.
Ruling
The Supreme Court set aside the dismissal of the claim and ordered respondent Pacific Metals Corporation to pay death compensation benefits, burial expenses, and attorney's fees to the widow and minor children of the deceased, as well as a sum to the Workmen's Compensation Fund.
Ratio Decidendi
On the compensability of the death: The Court held that the death of Cirilo Belarmino is compensable. It applied the 'proximity rule' established in Iloilo Dock & Engineering Co. (IDECO) v. Workmen's Compensation Commission and the principle from Luzon Stevedoring Corp. v. Workmen's Compensation Commission that injuries sustained from an assault by another employee or a third person are compensable if a rational mind can trace the injury to a cause set in motion by the nature of the employment or some condition therein. The fact that the incident occurred outside the premises and after working hours does not automatically preclude compensation, especially when the location is in close proximity to the employer's premises and the assault is work-connected. The Court found that the circumstances warranted the application of these rules, overturning the WCC's strict adherence to the 'going and coming rule' in this context. On the misappreciation of evidence: The Court found that the WCC committed a gross misappreciation of evidence by disregarding the widow's testimony. The widow testified that her husband had confided in her about difficulties in handling his subordinates and had a misunderstanding with Ponciano Angeles. This testimony was crucial in establishing a work-related motive for the assault. The Court noted that there was no motion to strike this testimony, and the employer failed to present evidence to rebut it. The lack of knowledge from the employer's witnesses about any misunderstanding was contrasted with the widow's positive testimony, which the Court held should prevail, especially in light of the subsequent assault by the subordinate on the supervisor.
Main Doctrine
The death of an employee caused by an assault from a co-employee, even if occurring after working hours and outside the employer's premises, is compensable under the Workmen's Compensation Act if the assault is work-connected, applying the 'proximity rule' and the principle that injuries sustained as a result of an assault are compensable where a rational mind can trace the injury to a cause set in motion by the nature of the employment.