Lasarte v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Narciso Lasarte, employed as a cashier with the Bureau of Public Highways, was killed on October 11, 1972. His widow, Gliceria Lasarte, and their six children filed a claim for death benefits against the Republic of the Philippines, asserting that Narciso's death occurred during his employment. Procedural History: The claim for death benefits was initially filed with Region Office V of the Department of Labor. An Acting Referee granted the claim, ordering the respondent to pay death compensation and burial expenses. The Republic of the Philippines appealed this decision to the Workmen's Compensation Commission, which reversed the Acting Referee's ruling and dismissed the claim, stating that Narciso Lasarte's death was not connected to his employment. The Petition: This case comes before the Supreme Court on a petition for review of the Workmen's Compensation Commission's decision. The petitioners argue that the Commission erred in dismissing the claim, contending that Narciso Lasarte's death, which was ruled a murder by the Criminal Investigation Service, occurred during his employment and is therefore presumed compensable under Section 44 of the Workmen's Compensation Act. They further assert that the respondent failed to present evidence to rebut this presumption.
Issue(s)
Whether the death of Narciso Lasarte, who was murdered, is compensable under the Workmen's Compensation Act. Whether the Workmen's Compensation Commission erred in reversing the decision of the Acting Referee.
Ruling
The Supreme Court set aside the decision of the Workmen's Compensation Commission and ordered the respondent to pay the claimants the sum of Six Thousand Pesos (P6,000.00) as death compensation plus burial expenses of Two Hundred Pesos (P200.00), and to pay the successor of the Workmen's Compensation Commission the sum of Sixty-One Pesos (P61.00) as administrative fee.
Ratio Decidendi
On whether the death of Narciso Lasarte is compensable: The Court held that the death of Narciso Lasarte, who was murdered while employed as a cashier, is presumed to be compensable under Section 44 of the Workmen's Compensation Act, as amended. This presumption arises because his death supervened during his employment. The Court emphasized that in cases where an employee's illness or death occurs during employment, it is presumed to have arisen out of, or at least been aggravated by, the employment. This presumption shifts the burden of proof to the employer to demonstrate otherwise. The Court noted that the investigators considered the killing as murder, indicating the circumstances attendant to the death. The fact that the deceased was employed as a cashier at the time of his death is crucial in establishing the connection to his employment. The Court reiterated the principle that the employer is relieved of the burden to show causation when this presumption is invoked. The respondent failed to present any evidence to rebut this presumption. Therefore, the death is compensable. On whether the Workmen's Compensation Commission erred: The Court found that the WCC erred in reversing the Acting Referee's decision. The WCC's assertion that the deceased's place of work was far from the place of death was found to be factually incorrect by the Supreme Court. The Court clarified that the II Engineering District of Albay, where Narciso Lasarte was assigned, had its office in Legazpi City, and the Village Restaurant and Hotel, where he was killed, was also located in Legazpi City, near his office. This factual correction undermined the WCC's basis for dismissing the claim. The Court applied the ruling in Simon vs. Republic of the Philippines, which states that even if the causal link between the employment and the ailment/death is not sufficiently shown, the presumption under Section 44 of the Workmen's Compensation Act still applies, and the burden shifts to the employer. Since the respondent failed to discharge this burden, the WCC's reversal was erroneous.
Main Doctrine
The death of an employee which supervened during his employment is presumed to have arisen out of, or at least been aggravated by, said employment, and the burden of proof to rebut this presumption shifts to the employer. The employer failed to discharge this burden.