G.R. No. L-13115; February 29, 1960
TRINIDAD DE LOS REYES VDA. DE SANTIAGO, for herself and in behalf of her minor children, MAMERTO, LEONILA and ANDREA, all surnamed SANTIAGO, petitioners, vs. ANGELA S. REYES and WORKMEN’S COMPENSATION COMMISSION, respondents.

FACTS

Petitioners filed a claim for compensation under the Workmen’s Compensation Act for the death of Victoriano Santiago, a jeepney driver employed by respondent Angela S. Reyes. On the evening of September 26, 1955, Santiago was last seen operating his jeepney within Manila, as required by his employer’s instructions and the Public Service Commission route authorization. His dead body was found the next morning in Tayabas, Quezon, with severe head fractures, evidently murdered by unknown persons. The employer had specific rules: drivers must follow the prescribed route within Manila and suburbs, with a fine imposed for route violations. The majority of the Workmen’s Compensation Commission denied the claim, finding that Santiago’s death did not arise out of and in the course of employment because he willfully violated the route instructions and Public Service Commission regulations by deviating to Quezon, thereby exposing himself to extra risks not inherent in his employment. Associate Commissioner Nieves Baens del Rosario dissented, emphasizing the statutory presumptions in favor of the employee under Section 43 of the Workmen’s Compensation Act.

ISSUE

Whether the death of Victoriano Santiago arose out of and in the course of his employment, entitling his heirs to compensation under the Workmen’s Compensation Act.

RULING

Yes. The Supreme Court reversed the decision of the majority of the Workmen’s Compensation Commission and granted the claim for compensation. The Court held that the presumptions under Section 43 of the Workmen’s Compensation Act, as amended, apply in favor of the claimant. Specifically, it is presumed that the claim comes within the Act’s provisions and that the injury was not occasioned by the willful intention of the employee. The majority of the Commission erred in concluding that Santiago voluntarily deviated from his route without substantial evidence to overcome these presumptions. Under Rule 123, Section 69(q) of the Rules of Court, there is a presumption that the ordinary course of business has been followed, meaning Santiago was presumed to have performed his duties legally and within his authorized route. The burden was on the employer to prove that Santiago willfully went beyond his route, but no such evidence was presented. Absent proof, the Court presumed that Santiago was forced by circumstances beyond his control—such as threats from malefactors—to drive to Quezon. This case is stronger than Batangas Transportation Co. vs. de Rivera (G.R. No. L-7658), where compensation was awarded despite indications of personal animosity, as here there are no such indications. Therefore, Santiago’s death is presumed to have arisen out of and in the course of his employment, and his heirs are entitled to compensation. The decision of the Commission is set aside, and the respondent is ordered to pay the compensation due.