Manila Railroad Company v. Manalang
REITERATIONFacts
The Antecedents: Ladislao Manalang was employed by Manila Railroad Company from October 27, 1926, to March 1, 1954. His last position was locomotive fireman. In March 1950, he vomited blood and was treated by the company physician, who discovered a spot in his left lung. He resumed work. In November 1953, he again vomited blood, took a leave, was treated by the chief physician, and subsequently retired on March 1, 1954, under disability retirement. On November 10, 1958, he filed a claim for compensation under the Workmen's Compensation Act. Procedural History: The Regional Office of the Department of Labor awarded P4,000.00 in compensation benefits. The Workmen's Compensation Commission (WCC) affirmed this award and ordered the company to pay P300.00 as attorney's fees. A motion for reconsideration was denied by the WCC en banc. The Petition: Manila Railroad Company filed a petition for review with the Supreme Court, questioning the jurisdiction of the Regional Office, the timeliness of the claim, the merits of the claim regarding the illness arising from employment, and the award of attorney's fees.
Issue(s)
Whether the Regional Office of the Department of Labor had the power to hear the claim for compensation. Whether the claim for compensation was barred by prescription under Section 24 of the Workmen's Compensation Act. Whether the claimant's illness (pulmonary tuberculosis) arose out of, or was aggravated by, his employment. Whether attorney's fees could be awarded to the claimant's counsel.
Ruling
The Supreme Court affirmed the decision and resolution of the Workmen's Compensation Commission, with costs against the petitioner.
Ratio Decidendi
On the jurisdiction of the Regional Office: The Court held that regional offices of the Department of Labor are vested with jurisdiction to hear and decide claims for compensation under the Workmen's Compensation Act, settling the petitioner's first contention. On the prescription of the claim: The Court agreed with the respondent Commission that the failure of the company to file a controversion of the claim within the time fixed by Section 45 of the statute is a bar to questioning the late filing of the claim. The Court cited jurisprudence and legal scholars (Horovitz, Larson) stating that the defense of notice and claim can be waived and is not jurisdictional. The Court reiterated its ruling in Century Insurance Co. v. Fuentes and National Development Corporation v. Workmen's Compensation Commission that the timeliness of notice or claim is not jurisdictional and failure to file a timely controversion bars all defenses, including the employee's failure to file the claim in due time. On the merits of the claim: The Court found that the Commission's findings of fact, supported by substantial evidence, were binding. These findings indicated that the nature of the claimant's work exposed him to extreme heat from the locomotive engine, sudden changes in temperature, and sleeping on concrete benches, which conditions gradually lowered his resistance, enabling the tubercle bacilli to develop and culminate in hemoptysis. Therefore, the claimant's sickness of pulmonary tuberculosis was deemed a result of the nature of his employment. On the award of attorney's fees: The Court rejected the petitioner's contention that only Section 31 of the Workmen's Compensation Law should apply. The Court held that precisely because Section 31 does not provide for the recovery of attorney's fees from the company, Article 2208(8) of the New Civil Code applies to supplement the deficiency in the Workmen's Compensation Act, in accordance with Article 18 of the New Civil Code, citing National Development Corporation v. WCC.
Main Doctrine
Failure of an employer to file a controversion within the period prescribed by Section 45 of the Workmen's Compensation Act constitutes a waiver of the right to controvert the claim, including defenses based on prescription or the employee's failure to file the claim in due time. The timeliness of notice or claim under Section 24 of the Act is not jurisdictional.