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    Enao Vs ECC. GR. L-46046. Apr. 5, 1985

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    theamorerosa
    1) Emelita Enao, a public school teacher, was injured in an ambush by armed men while traveling with co-teachers to procure school supplies. 2) She filed a claim for income benefits which was denied by the Employees' Compensation Commission and the GSIS. 3) The Supreme Court ruled in favor of Enao, finding that her injuries were work-connected under the special errand doctrine as she was performing her official functions in procuring supplies, even if outside regular hours and premises. 4) The GSIS was ordered to grant Enao's claim for loss of income benefits and pay the ascertained amount due.

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    Enao Vs ECC. GR. L-46046. Apr. 5, 1985

    Uploaded by

    theamorerosa
    37 views1 page
    1) Emelita Enao, a public school teacher, was injured in an ambush by armed men while traveling with co-teachers to procure school supplies. 2) She filed a claim for income benefits which was denied by the Employees' Compensation Commission and the GSIS. 3) The Supreme Court ruled in favor of Enao, finding that her injuries were work-connected under the special errand doctrine as she was performing her official functions in procuring supplies, even if outside regular hours and premises. 4) The GSIS was ordered to grant Enao's claim for loss of income benefits and pay the ascertained amount due.

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    Labor Law

    Original Title

    88. Enao vs ECC. GR. L-46046. Apr. 5, 1985_

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    1) Emelita Enao, a public school teacher, was injured in an ambush by armed men while traveling with co-teachers to procure school supplies. 2) She filed a claim for income benefits which was denied by the Employees' Compensation Commission and the GSIS. 3) The Supreme Court ruled in favor of Enao, finding that her injuries were work-connected under the special errand doctrine as she was performing her official functions in procuring supplies, even if outside regular hours and premises. 4) The GSIS was ordered to grant Enao's claim for loss of income benefits and pay the ascertained amount due.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    37 views1 page

    Enao Vs ECC. GR. L-46046. Apr. 5, 1985

    Uploaded by

    theamorerosa
    1) Emelita Enao, a public school teacher, was injured in an ambush by armed men while traveling with co-teachers to procure school supplies. 2) She filed a claim for income benefits which was denied by the Employees' Compensation Commission and the GSIS. 3) The Supreme Court ruled in favor of Enao, finding that her injuries were work-connected under the special errand doctrine as she was performing her official functions in procuring supplies, even if outside regular hours and premises. 4) The GSIS was ordered to grant Enao's claim for loss of income benefits and pay the ascertained amount due.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 1

    GR. L-46046 APR.

    5, 1985
    EMELITA ENAO vs. THE EMPLOYEES’ COMPENSATION COMMISSION

    NOTE: SPECIAL ERRAND DOCTRINE (LABOR LAW CASE)

    FACTS:

    Emelita Enao, a public-school teacher, together with her co-teachers, was on her way from her official
    station at Zamboanga del Norte to Dipolog City for the purpose of securing supplies and other training
    and school aids necessary for furthering the services of schoolteachers. They were ambushed and fired
    upon by armed men believed to be communist insurgents, hitting her on her forearm and abdomen,
    necessitating her operation. She later developed interstitial pneumonia as a result.

    In 1975, Enao sent a notice of claim of injury to the Sec. of Education and Culture. Her claim however
    was not controverted. On the same date, she filed a claim for income benefits for disability with the
    GSIS but was likewise denied by the System.

    Enao appealed to the Employees’ Compensation Commission (ECC). The latter affirmed the decision of
    the GSIS and dismissed petitioner’s claim on the ground that: a) her injury was incurred not during
    officer hours; b) she incurred injury outside school premises; and c) she was on her way home from
    her station.

    Hence, this petition for review before the SC, where petitioner contends that ECC had decided the claim
    in a way not in accordance with law.

    ISSUE/S:

    Main Issue:
    W/N petitioner Enao can claim for income benefits for disability with the GSIS. (YES)

    Other Issues:
    a) W/N her injury was incurred during office hours;
    b) W/N her injury was incurred outside school premises; and
    c) W/N she was on her way home in Dipolog City from work.

    RULING:

    The SC held in the POSITIVE. It disagrees with ECC’s findings that the statements of petitioner and her
    witnesses (co-teachers in the ambush) are self-serving declarations. The statements given by
    petitioner’s witnesses constitute prima facie evidence of the matter sought to be established.

    The conjecture in the decision of ECC that petitioner obtained self-serving declaration of her witnesses
    “in anticipation of a future litigation” is unfair and untenable.

    The fact that Dipolog City is also the residence of petitioner does not render untrue or false the clear
    evidence submitted in the case that petitioner and her co-teachers were proceeding to Dipolog City at
    the time to purchase needed supplies and other training and school aids. This fact becomes simply
    incidental and/or purely coincidental.

    It can be rightfully ruled that petitioner was actually performing her official functions. It hardly matters
    whether such task which Enao was then engaged in or discharging, happened outside the regular
    working hours and not in her place of work. It is obvious that in proceeding to purchase school materials
    in Dipolog City, she would have to leave the school premises and her travel need not be during her
    usual working house. What is significant and controlling is that the injuries she sustained are work-
    connected, which the SC finds to be so.

    WHEREFORE, decision of ECC is SET ASIDE. GSIS is ordered to grant Enao’s claim for loss of income
    benefits and to process and ascertain the total amount due to her, and thereafter to pay the same.

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