Luzon Stevedoring Corporation v. Workmen's Compensation Commission
REITERATIONFacts
1. The Antecedents: Pantaleon Hayson, an employee of Luzon Stevedoring Corporation, died on February 17, 1970, due to poisoning. While on duty as a gang boss on board the M/V President Aguinaldo on the evening of February 16, 1970, Hayson and his co-workers were offered a bottle of Tanduay Rhum by the ship's 3rd Officer. Upon drinking, they discovered the bottle contained oil of wintergreen, not rum. Hayson subsequently complained of stomach pain and was taken to the hospital, where he passed away. The attending physician and an autopsy confirmed poisoning as the cause of death. It was also established that Hayson was not a heavy drinker and was legally married with two children. 2. Procedural History: The widow of Pantaleon Hayson filed a claim for compensation benefits. A Workmen's Compensation Commission (WCC) Referee ruled that Hayson's death arose out of and in the course of his employment and awarded compensation and burial expenses to the widow and children, along with attorney's fees and WCC fees. The employer, Luzon Stevedoring Corporation, filed a motion for reconsideration, arguing that Hayson was notoriously negligent and thus his death was not compensable. The Referee denied this motion. The case was elevated to the WCC en banc, which affirmed the Referee's decision on July 16, 1973. Luzon Stevedoring Corporation then sought reconsideration from the WCC, which was denied on October 11, 1973. 3. The Petition: Luzon Stevedoring Corporation filed this petition for review on certiorari with the Supreme Court, seeking to overturn the WCC's decision. The sole issue presented is whether Pantaleon Hayson's death, resulting from accidentally ingesting oil of wintergreen mistaken for rum, falls within the coverage of the Workmen's Compensation Act. The petitioner contends that Hayson was notoriously negligent because he continued to drink from the bottle even after his companions discovered its contents. The petitioner argues that this constituted a deliberate disregard for his own safety, exempting the company from liability. The petition seeks a reversal of the WCC's affirmation of the compensation award.
Issue(s)
Whether the death of Pantaleon Hayson due to accidental poisoning falls within the coverage of the Workmen's Compensation Act. Whether the deceased was guilty of notorious negligence that would exempt the employer from liability.
Ruling
The decision of the Workmen's Compensation Commission is AFFIRMED. The death of Pantaleon Hayson is compensable under the Workmen's Compensation Act.
Ratio Decidendi
On the issue of compensability under the Workmen's Compensation Act: The Court affirmed the WCC's ruling that the death of Pantaleon Hayson arose out of and in the course of his employment. The act of drinking from the bottle, even if it contained oil of wintergreen, was considered reasonably necessary for the employee's comfort and health while at work, such as satisfying thirst or alleviating the cold. Such acts are incidental to employment, and injuries sustained in performing them are compensable. The conditions for compensability were met: the injury was received during the period of employment, the worker was at the place where his work required him to be, and he was doing something in pursuance of his work. The presumption of compensability applies, especially when the employee dies while in line of duty or at work, and any doubt must be resolved in favor of the claimant. On the issue of notorious negligence: The Court agreed with the WCC that the deceased was not guilty of notorious negligence. Notorious negligence requires an entire want of care, raising a presumption that the person is conscious of the probable consequences of his carelessness and is indifferent to the danger, practically equivalent to an intentional wrong. In this case, the deceased was not a heavy drinker and could not distinguish the taste of oil of wintergreen from rum. There was no evidence that he was aware of the probable fatal consequences of his act or that he intended to end his life. His act of drinking was what ordinary persons might do under the circumstances, especially on a cold night while waiting for work. Even if he drank after being told it was oil of wintergreen, there was no showing he admitted knowledge of its fatal nature or that his companions warned him of the danger. Therefore, his attitude constituted simple negligence, which is well within the compensatory coverage of the Act, not notorious negligence that would exempt the employer.
Main Doctrine
Death resulting from accidental poisoning due to mistaking oil of wintergreen for liquor, when the employee was not aware of the probable consequences and there was no intent to commit suicide, constitutes simple negligence and is compensable under the Workmen's Compensation Act, as it arises out of and in the course of employment.