Bondoc v. Worker's Compensation Comm'n

In Bondoc v. Worker's Compensation Comm'n, 2000 Guam 6, an injured employee sought review of the Worker's Compensation Commission's determination that he was ineligible for the benefits under the Worker's Compensation Act. The court was faced with inconsistent conclusions that the Commission had generated while applying the "Relative Nature of the Work Test" to determine whether Bondoc was entitled to worker's compensation coverage. The court took no position as to the appropriateness of the test but instead sought to demonstrate the inconsistent manner in which it was applied. Bondoc, 2000 Guam 6, at P 12, n.6. However, it has been stated that, in the context of worker's compensation statutes, courts have given substantial weight to the interpretation of an expert administrative agency. See Sutherland Stat. Const. 73.02 (5th ed.). Although a court generally observes this rule of deference, it need not defer to the agency's interpretation when the meaning of the statute is clear and unambiguous. Id.