Filipino Pipe & Foundry Corp. v. Workmen's Compensation Comm'n
REITERATIONFacts
The Antecedents: Guillermo Hiwatig, an employee of Filipino Pipe & Foundry Corporation, filed a claim for compensation due to temporary total disability allegedly caused by an accident on May 3, 1961, while working on the employer's premises. Notice of the accident was given to the company physician on the same date. Procedural History: On February 5, 1962, the Regional Commissioner of the Department of Labor issued an award in favor of Hiwatig, considering the claim uncontroverted due to the employer's failure to contest it within the reglementary period. The award directed the employer to pay compensation and costs. Petitioner's subsequent "petition for new hearing" filed on March 5, 1962, and a "Petition for relief from judgment" filed on June 16, 1962, were denied by the respondent Commission. The Petition: Petitioner filed an original action for certiorari with the Supreme Court, arguing that the award was made without notice and hearing, thus denying due process, and that it had no plain, speedy, and adequate remedy in the ordinary course of law.
Issue(s)
Whether the award made by the Workmen's Compensation Commission is void for lack of due process. Whether the petitioner was entitled to a new hearing or relief from judgment.
Ruling
The petition for certiorari is denied, and the case is dismissed. The award made by the respondent Workmen's Compensation Commission is upheld.
Ratio Decidendi
On Issue 1 (Due Process and Award Validity): The Court held that the petitioner was not denied due process. It was undisputed that the petitioner failed to file its answer or controvert the claim within the ten (10) days from notice, as required by Section 45 of Act No. 3428. This failure resulted in the claim being deemed admitted by the petitioner, thereby forfeiting its right to demand a day in court. The Court emphasized that the petitioner must suffer the consequences of the omission or negligence of its own employee, Miss Villaluz, who failed to deliver the claim to the president on time. Therefore, the award, being based on an uncontroverted claim, was validly issued. On Issue 2 (New Hearing and Relief from Judgment): The Court found that the petitioner's subsequent procedural remedies were also procedurally infirm. The "petition for new hearing" was filed on March 5, 1962, more than fifteen (15) days after notice of the award on February 16, 1962. Under Section 50 of Act No. 3428, the award had become final and executory by then. Furthermore, this petition partook of the nature of a motion for relief from judgment, which was fatally defective for lacking an affidavit of merit, as required by Rule 38, Section 3 of the Rules of Court. The "petition for relief from judgment" itself was filed on June 16, 1962, which was more than sixty (60) days from notice of the award, thus exceeding the period allowed by Rule 38, Section 3 of the Rules of Court. The Court also noted that the petitioner had a plain, speedy, and adequate remedy in the ordinary course of law by timely filing its answer and defenses, and by availing of proper appeals from the denial of its motions, which it failed to do.
Main Doctrine
The Supreme Court affirmed that failure to file an answer or controvert a claim within the ten (10) days from notice, as mandated by Section 45 of Act No. 3428, results in the claim being deemed admitted and the employer forfeiting its right to contest it. Furthermore, the Court reiterated that petitions for new hearing or relief from judgment must be filed within the prescribed periods and must comply with procedural requisites, such as attaching an affidavit of merit, to be considered valid. The case underscores the principle of due process in administrative proceedings, balanced with the need for finality of judgments when procedural rules are not observed.