Lazo vs. Employees' Compensation Commission

Injuries sustained by an employee in a vehicular accident while on the way home from work are compensable under PD 626 as arising out of and in the course of employment, provided the employee was on his usual homeward route without deviation or interruption, the employees' compensation law being social legislation that must be liberally construed in favor of labor.

Salvador Lazo was a security guard of the Central Bank of the Philippines assigned to its main office in Malate, Manila, with a regular tour of duty from 2:00 p.m. to 10:00 p.m. He resided in Binangonan, Rizal. His claim for disability benefits was filed under Presidential Decree No. 626, as amended, the employees' compensation law which replaced the Workmen's Compensation Act. The GSIS and the ECC serve as the initial adjudicator and appellate body, respectively, for government employees' compensation claims.

Salvador Lazo was a security guard of the Central Bank of the Philippines assigned to its main office in Malate, Manila, with a regular tour of duty from 2:00 p.m. to 10:00 p.m. On June 18, 1986, petitioner rendered his regular shift, but the security guard scheduled to relieve him failed to arrive. Consequently, petitioner rendered overtime duty until 5:00 a.m. of June 19, 1986, at which point he asked permission from his superior to leave early in order to take home to Binangonan, Rizal, his sack of rice.

At approximately 6:00 a.m. on June 19, 1986, while on his way home, the passenger jeepney petitioner was riding turned turtle due to a slippery road. He sustained injuries and was taken to the Angono Emergency Hospital for treatment, and was later transferred to the National Orthopedic Hospital where he was confined until July 25, 1986.

For the injuries sustained, petitioner filed a claim for disability benefits under PD 626, as amended. The GSIS denied the claim, finding that petitioner was not at his workplace performing his duties when the incident occurred, having left the office to attend to a personal matter — bringing home a sack of rice. Upon review, the ECC affirmed the dismissal, holding that the accident occurred far from the work place and while petitioner was attending to a personal matter. Petitioner elevated the case to the Supreme Court, contending that his injuries should be deemed to have arisen out of and in the course of employment and thus compensable.

• Compensability of Commuting Injury: Petitioner contended that the injuries he sustained due to the vehicular accident on his way home from work should be construed as "arising out of or in the course of employment" and thus compensable under PD 626.
• Applicable Precedent: Petitioner cited Baldebrin vs. Workmen's Compensation Commission, where compensation was awarded to an employee who figured in an accident on his way home from his official station, as controlling authority supporting his claim.

• Inapplicability of Baldebrin: Respondents claimed that the Baldebrin ruling was a deviation from earlier decided cases and therefore should not be applied to the present case.
• Absence of Work Connection: Respondents maintained that the accident occurred far from petitioner's work place and while he was attending to a personal matter, thus failing the condition for compensability.

• Compensability: Whether injuries sustained by an employee in a vehicular accident while on his way home from work — including overtime — are compensable under PD 626 as "arising out of or in the course of employment."

• Compensability: Yes. The injury is compensable, employment being construed to include a reasonable margin of time and space necessary for passing to and from the place of work, and the employees' compensation law being social legislation that must be liberally interpreted in favor of labor.

• Compensability: The Court applied the established doctrine, drawn from a line of cases, that employment includes not only the actual doing of work but a reasonable margin of time and space necessary to be used in passing to and from the workplace. In Baldebrin vs. Workmen's Compensation Commission, compensation was awarded to an employee injured on his way home from his official station. In Vda. de Torbela vs. ECC, the Court held that when an employee is accidentally injured at a point reasonably proximate to the place of work while going to or from work, the injury is deemed to have arisen out of and in the course of employment. In Alano vs. ECC, the Court reiterated this principle, holding that the employee was at the place where her employment required her to be. In Vano vs. GSIS & ECC, compensation was awarded to an employee on his way to work one day before an official working day. The Court found no reason to deviate from these rulings. Petitioner had come from work and was on his way home, just as in Baldebrin. There was no evidence that petitioner deviated from his usual, regular homeward route or that interruptions occurred in the journey. While the presumption of compensability and theory of aggravation under the Workmen's Compensation Act may have been abandoned under the New Labor Code, the liberality of the law in favor of the workingman still subsists. The ECC should adopt a liberal attitude in favor of the employee, especially where there is some basis in the facts for inferring a work connection. This interpretation gives meaning to Article 4 of the Labor Code, which mandates that all doubts in the implementation and interpretation of the Labor Code shall be resolved in favor of labor. There is no reason in principle why employees should not be protected for a reasonable period of time and distance prior to or after working hours. If Vano awarded compensation to an employee on his way to work one day before a working day, there is no reason to deny compensation for accidental injury occurring while on the way home one hour after leaving the work station.

• Going-to-and-Coming-From-Work Doctrine — Employment includes not only the actual doing of the work but a reasonable margin of time and space necessary to be used in passing to and from the place where the work is to be done. If the employee is injured while passing, with the express or implied consent of the employer, to or from work, the injury is one arising out of and in the course of employment. The Court applied this doctrine to petitioner, who was on his way home from work without deviation from his usual route.
• Liberal Interpretation of Social Legislation — The Employees Compensation Act, like the Workmen's Compensation Act, is basically social legislation designed to afford relief to working men and women. All doubts in the implementation and interpretation of the Labor Code, including its implementing rules and regulations, shall be resolved in favor of labor pursuant to Article 4 of the Labor Code. The policy is to extend the applicability of PD 626 to as many employees who can avail of its benefits, in consonance with the State's avowed policy to give maximum aid and protection to labor.

• "There is no reason, in principle, why employees should not be protected for a reasonable period of time prior to or after working hours and for a reasonable distance before reaching or after leaving the employer's premises." — This passage articulates the Court's rationale for extending compensability to the commuting period, forming the core of the ratio decidendi.
• "While the presumption of compensability and theory of aggravation under the Workmen's Compensation Act (under which the Baldebrin case was decided) may have been abandoned under the New Labor Code, it is significant that the liberality of the law in general in favor of the workingman still subsists." — This passage reconciles the shift from the Workmen's Compensation Act to PD 626 while preserving the pro-labor interpretive orientation, a point frequently cited in subsequent employees' compensation jurisprudence.
• "As agent charged by the law to implement social justice guaranteed and secured by the Constitution, the Employees Compensation Commission should adopt a liberal attitude in favor of the employee in deciding claims for compensability, especially where there is some basis in the facts for inferring a work connection to the accident." — This passage defines the standard of review the ECC must apply, directing the administrative body to construe the law compassionately in favor of claimants.

• Baldebrin vs. Workmen's Compensation Commission, G.R. No. L-43792, October 12, 1984, 132 SCRA 510 — Controlling precedent directly on point. The Court awarded compensation to an employee injured on his way home from his official station, establishing the principle that commuting injuries are compensable. The Court found the present case analogous, petitioner likewise having been on his way home from work.
• Vda. de Torbela vs. ECC, G.R. No. L-42627, February 21, 1980, 96 SCRA 260 — Followed. The Court held that when an employee is accidentally injured at a point reasonably proximate to the workplace while going to or from work, the injury arises out of and in the course of employment.
• Alano vs. ECC, G.R. No. L-48594, March 16, 1988, 158 SCRA 670 — Followed. The Court reiterated that an employee on the way to work is at a place where employment requires her to be, making the resulting injury compensable.
• Vano vs. GSIS & ECC, G.R. No. 81327, December 4, 1989 — Followed. Compensation was awarded to an employee on his way to work one day before an official working day. The Court used this case to argue that if compensation was granted for an employee traveling to work a day early, it should likewise be granted to an employee traveling home one hour after leaving work.
• Philippine Engineer's Syndicate, Inc. vs. Martin and Workmen's Compensation Commission, 4 SCRA 356 — Cited within Baldebrin for the proposition that an employee injured while attempting to board a company truck near his place of work after working hours suffered a compensable injury.
• Iloilo Dock & Engineering Co. vs. Workmen's Compensation Commission, 26 SCRA 102 — Cited within Baldebrin for the canonical formulation that employment includes a reasonable margin of time and space necessary for passing to and from the workplace.

• Presidential Decree No. 626, as amended (Employees Compensation Decree) — The governing employees' compensation law under which petitioner filed his claim. The Court interpreted its compensability provisions liberally in favor of labor, extending coverage to injuries sustained during the reasonable commute to and from work.
• Article 4, Labor Code of the Philippines — Provides that all doubts in the implementation and interpretation of the provisions of the Labor Code, including its implementing rules and regulations, shall be resolved in favor of labor. The Court invoked this provision as the textual basis for liberal construction of the employees' compensation law.

Melencio-Herrera (Chairperson), Paras, Sarmiento, and Regalado, JJ., concurred.