Case Digest: Valeriano vs. ECC and GSIS

Valeriano vs. ECC and GSIS, June 8, 2000 GR 136200

Facts:

Celestino Valeriano was employed as a firetruck driver. On the evening of July 3, 1985, after having dinner with a friend, Valeriano met an accident  and was severely injured when the vehicle he was on collided with another. Valeriano claimed for benefits from the GSIS which the latter denied for being non-compensable. The ECC and CA sustained the system, reasoning that the injury resulted not from an accident arising out of and in the course of employment nor was it work-connected.

Issue: Whether or not the injuries sustained by Valeriano in the collision was compensable.

Ruling:

Valeriano’s injuries were non-compensable.

Valeriano’s contention, citing the Hinoguin and Nitura cases, that the 24-hour doctrine be applied to his case since the exigency of his job demand it to be so was held untenable by the Court. The Court did not find any reasonable connection between his injuries and his work as a firetruck driver. Applying the principle laid down in the Alegre case, the 24-hour doctrine is not meant to embrace all acts and circumstances of an employee though he be on active “on call” duty. Valeriano was neither at his assigned work place nor in pursuit of the orders of his superiors when he met the accident.  He was also not doing an act within his duty and authority as a firetruck driver, or any other act of such nature, at the time he sustained his injuries. In fact, he was pursuing a purely personal and social function when the accident happened. The accident not work-connected was, therefore, non-compensable.

Categories: 2000 GR 136200, compensability, June 8, Valeriano vs. ECC and GSIS, work-connected accidents