LILIA B. GALCERAN, PETITIONER, VS. SECRETARY OF LABOR & THE HI-CEMENT CORPORATION, RESPONDENTS.
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Galceran versus Hi-Cement Corporation
The Case
This is a petition for review brought by Lilia Galceran, the surviving widow of Noel Galceran, against the Secretary of Labor and the Hi-Cement Corporation. The widow seeks to reverse the Secretary of Labor's denial of her claim for death compensation under the Workmen's Compensation Act. The case matters because it confronts a question that recurs in compensation law: whether a suicide that follows a work-connected injury is compensable when the injury itself produced the insanity that drove the worker to take his own life. It is a study in the liberal interpretation of the Workmen's Compensation Act in favor of the working man and his dependents, anchored on the social justice provision of the Constitution.
Procedural History
The widow filed a notice and claim for death compensation with the Department of Labor, Regional Office Number Four, Workmen's Compensation Section. At the initial hearing, the Acting Referee required the counsels for both parties to submit their respective affidavits simultaneously. The Acting Referee then issued an order dismissing the claim, on the view that suicide is not compensable. The widow's counsel later filed a motion to set the case for hearing, on the ground that he never received any notice of hearing or an order of dismissal. The Secretary of Labor denied this motion, citing that the case was already dismissed. A motion for reconsideration of the order of dismissal was likewise denied for lack of merit by the Secretary of Labor. The widow then brought the present petition for review before the Supreme Court, raising the issue that the suicide was an after-effect of the accident and that the death was therefore work-connected and compensable.
Facts
Noel Galceran had been an employee of the Hi-Cement Corporation since 1968, working as a pre-heater operator with a daily wage of nine pesos and eighty centavos. On May 17, 1970, while inside the corporation's factory, his helmeted head was caught by the drive V-belts of the plant's kiln pre-heater. The belts dragged his whole body and smashed him against the wheel, causing extensive injuries to his head, neck, and body.
He was brought by his employer to the ABM Sison Hospital and confined there from May 17 to July 20, 1970. The report of his injuries to the Social Security System showed extensive avulsion with lacerations and loss of tissues of the scalp and neck, and severe cerebral concussion. According to his wife, he later became insane, and on August 5, 1970, he committed suicide by hanging himself. The death certificate shows that he died of asphyxia due to strangulation, suicidal.
On March 31, 1975, the widow filed her claim for death compensation. The Acting Referee dismissed the claim, and the Secretary of Labor denied both the motion to set the case for hearing and the motion for reconsideration. To support her claim that her husband was out of his mind when he took his life, the widow submitted the opinion of Dr. Benvenuto Juatco, who opined that the brain injury resulted in mental deterioration and that the suicidal act was done in a moment of mental loss, so that the death was work-connected. The respondents countered that there was no evidence that the deceased became insane, and assailed the medical opinion because the physician never attended the deceased and was never presented at a hearing.
Issues
- Whether or not the suicide of Noel Galceran was an after-effect of the work-connected accident, such that his death is compensable under the Workmen's Compensation Act.
- Whether or not the evidence on record, including the widow's affidavit and the medical opinion of Dr. Juatco, is adequate to establish that the deceased was insane at the time he committed suicide and was thus incapable of forming a willful intention to take his own life.
- Whether or not the medical opinion may be considered despite the physician not having attended the deceased and not having been presented at a hearing.
Applicable Provisions
Section 2 of the Workmen's Compensation Act, as amended, provides:
Section 2. Grounds for compensation. When an employee suffers personal injury from any accident arising out of and in the course of his employment, or contracts tuberculosis or other illness directly caused by such employment or either aggravated by or the result of the nature of such employment, his employer shall pay compensation in the sums and to the person hereinafter specified. The right to compensation as provided in this Act shall not be defeated or impaired on the ground that the death, injury or disease was due to the negligence of a fellow servant or employee, without prejudice to the right of the employer to proceed against the negligent party.
This provision supplies the ground for compensation, since the deceased suffered personal injury from an accident arising out of and in the course of his employment.
Section 4 of the same Act provides:
Section 4. Injuries not covered. Compensation shall not be allowed for injuries caused (1) by the voluntary intent of the employee to inflict such injury upon himself or another person; (2) by drunkenness on the part of the laborer who had the accident; (3) by notorious negligence of the same.
This provision is the exclusion the Court must construe, because the respondents invoke the voluntary intent of the employee to inflict injury upon himself as a bar to the claim.
Ruling
On the first issue, the Court held that the death is compensable. It is not disputed that the deceased sustained physical injuries when he met an accident inside the company's plant in the course of his employment. The severe cerebral concussion, the lacerated scalp, and the other injuries suffered when the worker's head hit the wheel were compatible with and logically related to the resulting insanity which followed fairly closely afterward. Insanity is a disease reasonably attributable to the nature of the injuries sustained by the worker. Because of the social justice provision of the Constitution and the consistently liberal interpretation of the Workmen's Compensation Act in favor of the working man and his dependents, the Court followed the rule that where the injuries precipitate mental derangement which, in turn, causes the suicide, the death is compensable. The Court quoted the statutory exclusion it was construing:
Compensation shall not be allowed for injuries caused (1) by the voluntary intent of the employee to inflict such injury upon himself or another person.
The Court reasoned that where the original work-connected injuries result in the employee becoming devoid of normal judgment and dominated by a disturbance of mind directly caused by his injury and its consequences, the self-inflicted injury cannot be considered purposeful within the meaning and intent of the Workmen's Compensation Act. Where an employee becomes mentally deranged and deprived of normal judgment as a result of a compensable accident and commits suicide in consequence, his act is not willful within the meaning of the Act.
On the second issue, the Court held that the substantial evidence rule, and not the preponderance of evidence rule, governs the determination of compensability of an injury or illness. It found the affidavit of the widow as well as the opinion of Dr. Juatco adequate proof that the worker was insane at the time he committed suicide and that this insanity rendered him incapable of forming a willful intention to take his own life.
On the third issue, the Court rejected the objection to the medical opinion. The records reveal that the only hearing held was the one at which the counsels were required to submit their respective affidavits, and the widow's motion to set the case for hearing was denied, so she never had a chance to present the evidence establishing the medical link between the insanity and the death. Moreover, the problem in workmen's compensation cases is not the admissibility of evidence which is incompetent under the ordinary legal rules, but the efficacy of such evidence to support an award or decision. The admission of incompetent evidence is not in itself ground for reversal of an award.
Doctrine
Where the work-connected injuries precipitate mental derangement which, in turn, causes the suicide, the death is compensable. The self-inflicted injury is not purposeful or willful within the meaning of Section 4 of the Workmen's Compensation Act, because the employee, being devoid of normal judgment and dominated by a disturbance of mind directly caused by his injury and its consequences, is incapable of forming a voluntary intent to inflict injury upon himself. Compensability is determined under the substantial evidence rule, not the preponderance of evidence rule, and the liberal interpretation of the Workmen's Compensation Act in favor of the working man and his dependents, grounded on the social justice provision of the Constitution, governs the construction of its exclusions.
Disposition
The Court set aside the order of the Acting Referee dismissing the claim and directed the Hi-Cement Corporation to pay the petitioner and her daughter six thousand pesos as compensation, two hundred pesos as burial expenses, and six hundred twenty pesos as attorney's fees, plus sixty-one pesos as administrative fees.
Remember This
The single line worth memorizing is that where the work-connected injury precipitates insanity that causes the suicide, the death is compensable, because the act is not willful within the meaning of the Workmen's Compensation Act. Examiners like to use this case to test the substantial evidence rule in compensation proceedings and the liberal, social-justice reading of the statutory exclusions for self-inflicted injury.