General Shipping Co. v. Workmen's Compensation Commission
REITERATIONFacts
1. The Antecedents: This case concerns a claim for death compensation filed by Marina Vda. de Ricardo, the widow of Ruperto Ricardo, who was employed as a ship engineer by General Shipping Co., Inc. The deceased allegedly died of heart failure on March 16, 1956, while aboard the M/S "General Roxas." The claimant asserted that her husband had been physically fit prior to his employment and that his strenuous work and exposure to hazards at sea for eight years led to the development of heart defects, ultimately causing his death. She also claimed P380.00 for burial expenses. 2. Procedural History: Marina Vda. de Ricardo filed a claim for compensation under Act No. 3428 with the Workmen's Compensation Commission on June 11, 1956. The employer, General Shipping Co., Inc., submitted its Employer's Report of Accident or Sickness on September 27, 1956, stating the deceased died of a heart attack while sleeping and that voluntary payments of P2,313.99 had been made. The Commission's Evaluation Division found no causal relationship between the heart attack and the employment. Despite this, the Chief Hearing Officer awarded the claimant P1,686.01 as death compensation balance and P200.00 for burial expenses. This decision was affirmed by Associate Commissioner Nieves Baens del Rosario and subsequently by the Workmen's Compensation Commission en banc, with Chairman Cesareo de Leon dissenting. 3. The Petition: General Shipping Co., Inc. filed a petition for certiorari with the Supreme Court, seeking to overturn the resolution of the Workmen's Compensation Commission. The sole issue presented is whether there is sufficient evidence to sustain the Commission's finding that the widow's claim is compensable. The petitioner argues that the Commission's decision is not supported by substantial evidence, particularly in light of the medical opinion from the Evaluation Division. The petition challenges the compensability of the death, implying a lack of causal connection between the employment and the heart failure.
Issue(s)
Is there sufficient evidence to sustain the Workmen's Compensation Commission's finding that the widow's claim for the death of Ruperto Ricardo is compensable?
Ruling
The Supreme Court affirmed the resolution of the Workmen's Compensation Commission, holding that the claim is compensable. The Court found that the employer's failure to report the death within the statutory period and its voluntary payment of compensation constituted a renunciation of its right to controvert the claim, thereby constructively admitting its compensability. The Court also noted that the employer did not controvert the claim that the deceased's strenuous work developed the heart disease which caused his death.
Ratio Decidendi
On the issue of compensability: The Supreme Court ruled that the employer's failure to controvert the claim in a timely manner, as well as its voluntary payment of a portion of the compensation, constituted sufficient evidence to sustain the finding of compensability. The claim, filed on June 11, 1956, specifically alleged that the deceased's strenuous life and exposure to hazards aboard the vessel for seven years developed heart defects, which eventually led to his death. This statement was not disputed or controverted by the employer either in its initial report on September 27, 1956, or in its subsequent report, Annex "C", filed on September 27, 1957, which was explicitly made to controvert the claim. Pursuant to Section 45 of Act No. 3428, as amended, the company's failure to report the death to the Commission within the statutory period of 14 days after the death or 10 days after notice thereof, constituted a renunciation of its right to controvert the claim, thereby constructively admitting its compensability, as held in Victorias Milling Co., Inc. vs. Compensation Commission, et al. (G.R. No. L-10533, May 13, 1957) and Tan Lim Te vs. Workmen's Compensation Commission et al. (55 Off. Gaz., [9] 1570). Furthermore, the record showed that the company had already made a voluntary payment of P2,313.99, which likewise indicated an admission of the compensability of the claim, in line with the ruling in Bachrach Motor Co. Inc. vs. Domingo Panaligan (99 Phil., 238; 52 Off. Gaz., [7] 3583). These actions and omissions of the company were considered admissions against interest, admissible in evidence against the respondent company under Section 7, Rule 123 of the Rules of Court, and were sufficient to establish the claim's compensability, rendering it unnecessary for the widow to present further proof. The Court emphasized that the finding of compensability by the Workmen's Compensation Commission involves an exercise of discretion, which should not be disturbed on appeal in the absence of abuse thereof.
Main Doctrine
An employer's failure to timely report an employee's death or sickness to the Workmen's Compensation Commission, or its voluntary payment of compensation, constitutes a renunciation of its right to controvert the claim, thereby constructively admitting its compensability.