Carlos v. De la Rosa
REITERATIONFacts
The Antecedents: Celso Aroyo, a laborer earning P4.00 daily, fell from a nine-meter scaffolding while working on the construction of a church in Sampaloc, Manila. He was found unconscious and died upon arrival at the North General Hospital. His employer was Ricardo Carlos, who had a contract with the Roman Catholic Archbishop of Manila for the construction. Aroyo's widow filed a claim for compensation. Procedural History: The Labor Regional Office No. 3 sent letters to Ricardo Carlos on June 24, 1959, and July 17, 1959, requesting the submission of the employer's report concerning the accident, as required by Section 37 of the Workmen's Compensation Act (No. 3428), as amended. Carlos failed to submit the report. On October 7, 1959, the regional administrator issued an award in favor of the claimant for P2,611.00, based on the police report and other records. Carlos received the award on January 11, 1960. Carlos filed a petition for reconsideration, alleging he was never summoned or notified of any hearing, thus the judgment was rendered without due process. This was denied. His subsequent petition for review with the Workmen's Compensation Commission was also denied, as was his appeal to the commission en banc. The Petition: Ricardo Carlos filed a petition for review, contending that the regional administrator and the Workmen's Compensation Commission acted without jurisdiction because the claim was heard without his notification or service of summons, violating due process.
Issue(s)
Whether the regional administrator and the Workmen's Compensation Commission acted without jurisdiction in deciding the claim for compensation due to alleged lack of notice and summons to the petitioner. Whether the petitioner waived his right to controvert the claim by failing to submit the required employer's report within the statutory period.
Ruling
The award appealed from is affirmed, without pronouncement as to costs.
Ratio Decidendi
On the issue of jurisdiction and lack of notice/summons: The Court affirmed the ruling of the Workmen's Compensation Commission. It found that the petitioner's contention of lack of due process due to not being summoned or notified was unsatisfactory because he had already waived his right to controvert the claim by failing to comply with the legal requirements. The right to controvert is only given to those who have not waived it. Therefore, the subsequent proceedings, even without formal summons, were valid in light of the petitioner's prior failure to act as required by law. On the issue of waiver of the right to controvert: The Court held that the petitioner waived his right to controvert the claim by failing to submit the required Employer's Report and Physician's Report within the statutory period. Section 45 of Act No. 3428, as amended, explicitly states that failure on the part of the employer to file a notice controverting the right to compensation within ten days after knowledge of the alleged accident constitutes a renunciation of his right to controvert the claim, unless reasonable grounds for the failure are submitted and accepted by the Commissioner. The petitioner failed to provide such reasonable grounds.
Main Doctrine
Failure of an employer to file a notice controverting the right to compensation within the statutory period constitutes a waiver of the right to controvert, and such waiver, by operation of law, does not violate the requirements of due process.