GSIS v. Angel

G.R. No. 166863 (July 20, 2011)

SC ruled Sgt. Angel's death not compensable under PD 626; "line of duty" not enough for claims.

Facts:

The case revolves around the death of Sergeant Benjamin Angel, who began his military training on July 1, 1974, and was admitted into active service on October 7, 1977. He rose through the ranks, becoming a Corporal in December 1982 and a Sergeant in July 1986, serving until his death on March 3, 1998. On the day of his death, Sgt. Angel was "invited" by Captain Fabie M. Lamerez of the Intelligence Service Group of the Philippine Army to provide information regarding his alleged involvement in a pilferage/gunrunning case. He was subsequently detained for further investigation.

The following day, Sgt. Angel was found dead in his cell, hanging with an electric cord around his neck. An autopsy report indicated that the cause of death was asphyxia by strangulation. His wife, Jum Angel, alleged that her husband was murdered and filed a complaint with the Philippine National Police (PNP), naming members of the Intelligence Service Group as suspects.

An investigation by the Office of the Provost Marshal concluded that Sgt. Angel's death was suspicious and recommended a court martial. However, the Inspector General later found no evidence of foul play, suggesting that the stress of detention could have led to suicide. Despite conflicting reports, the Judge Advocate General recommended that Sgt. Angel be declared to have died in the line of duty, which was subsequently affirmed by the Chief of Staff of the Philippine Army through General Order No. 270.

Following this declaration, Jum Angel filed a claim for death benefits with the Government Service Insurance System (GSIS) under Presidential Decree No. 626. The GSIS denied the claim, asserting that Sgt. Angel's death did not arise out of and in the course of employment. The Employees' Compensation Commission (ECC) upheld this denial, leading Jum Angel to appeal to the Court of Appeals.

Legal Issues:

  1. Whether the death of Sgt. Angel was compensable under Presidential Decree No. 626, given that it was determined to be in line of duty.
  2. Whether the Court of Appeals erred in reversing the ECC's decision that denied the claim for death benefits.

Arguments:

  • Petitioner (GSIS): The GSIS argued that Sgt. Angel's death did not arise out of and in the course of employment as defined by the implementing rules of Presidential Decree No. 626. They contended that the circumstances of his death were unrelated to his official duties, as he was being investigated for alleged misconduct at the time of his death.

  • Respondent (Jum Angel): Jum Angel contended that her husband's death was compensable because he was on active duty status, and the investigation was part of his official responsibilities. She argued that the declaration of his death as "in line of duty" by military authorities should suffice to establish compensability under the law.

Court's Decision and Legal Reasoning:

The Supreme Court ruled in favor of the GSIS, reversing the Court of Appeals' decision. The Court emphasized that for a death to be compensable under Presidential Decree No. 626, it must result from an accident arising out of and in the course of employment. The Court clarified that the term "accident" implies an unexpected event that occurs without intention or design.

The Court found that Sgt. Angel's death was not an accident but rather an intentional act, as he was found hanging in his cell. The Court noted that the conflicting findings regarding the cause of death—whether it was suicide or murder—did not alter the fact that the death was not accidental. The Court also stated that the military's declaration of "in line of duty" status did not equate to a finding that the death was caused by an accident.

The Court further highlighted that the proceedings before the military and the ECC were distinct, and the military's conclusions could not be used to establish entitlement to compensation under the Employees' Compensation Law. The Court concluded that the evidence did not support a claim of murder, and the circumstances surrounding Sgt. Angel's death did not meet the criteria for compensability.

Significant Legal Principles Established:

  1. The definition of "accident" in the context of employees' compensation law, emphasizing that it must be an unexpected event without intention or design.
  2. The distinction between military findings regarding "line of duty" status and the requirements for compensability under the Employees' Compensation Law.
  3. The necessity for a clear causal connection between the employee's death and their employment for benefits to be granted under the law.