Aboitiz Shipping Corporation v. Oqueria
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a claim for workmen's compensation filed by Demetria Oqueria and her minor children. The claim is based on the alleged death of Sofronio Buen, who was a seaman employed by petitioner Aboitiz Shipping Corporation. Buen disappeared from the M/V Carmen while it was navigating on the high seas near Kaubian Island on October 14, 1961. Despite a marine protest and futile attempts to recover his body, his whereabouts remain unknown. 2. Procedural History: Following Buen's disappearance, the petitioner failed to submit an employer's report of accident within the statutory period. Consequently, the Regional Labor Administrator issued an award on February 20, 1962, granting respondents P3,806.40 in compensation. The petitioner's motion to set aside this award was denied on May 14, 1962, for being filed out of time. A subsequent petition for review was denied by the Chairman of the Workmen's Compensation Commission on January 14, 1963, due to the untimeliness of the motion to set aside the award. A motion for reconsideration of this denial was also denied by the Commission en banc on February 19, 1963. 3. The Petition: The petitioner, Aboitiz Shipping Corporation, seeks review by certiorari of the order and resolution of the Workmen's Compensation Commission. The petitioner argues that the Commission erred in several points, including holding that the claim was uncontroverted, issuing the award without prior notice and hearing, presuming death from disappearance, and not considering the Employer's Report of Accident as timely filed. Furthermore, the petitioner contends that notice of the award should have been served on its counsel, not the company itself, and that the award had not yet become final and executory.
Issue(s)
Whether the Workmen's Compensation Commission erred in holding that petitioner had not controverted the claim for compensation in this case. Whether the award of February 20, 1962, and the order of May 14, 1962, denying the petition to set aside said award, are illegal and invalid for having been made without previous notice and hearing. Whether the Workmen's Compensation Commission erred in impliedly presuming the death of Buen in consequence of his disappearance from petitioner's vessel. Whether the filing by petitioner of the Employer's Report of Accident or Sickness on January 30, 1962, had satisfied the requirements of Section 1, Rule 14 of the Rules of the Workmen's Compensation Commission. Whether the Workmen's Compensation Commission erred in sending a copy of the award dated February 20, 1962, to petitioner's manager, instead of to petitioner's counsel, thereby contravening Section 2, Rule 27 of the Rules of Court. Whether the reglementary period to seek a review of such award commenced to run from receipt of notice thereof by petitioner's counsel. Whether the Workmen's Compensation Commission erred in concluding that said award has already become final and executory and in affirming said award.
Ruling
The Supreme Court affirmed the order and resolution of the Workmen's Compensation Commission, holding that the award had become final and executory.
Ratio Decidendi
On Issue 1: The Court held that the petitioner had renounced its right to controvert the claim. It was undisputed that Sofronio Buen disappeared from the vessel on October 14, 1961, and the petitioner was aware of this fact on the same date. However, the petitioner did not file the corresponding Employer's Report of Accident within the statutory period of fourteen (14) days from the date of the accident or within ten (10) days after acquiring knowledge thereof. The report was only submitted on January 30, 1962, which was 108 days after the accident. Furthermore, the petitioner failed to submit any reasonable grounds to justify or explain this failure to file the report within the statutory period. Therefore, pursuant to the second paragraph of Section 45 of the Workmen's Compensation Act, as amended, the petitioner is deemed to have renounced the right to controvert the claim for compensation, notwithstanding any statement to the contrary in the belatedly filed report. This reiterates the established jurisprudence found in cases like National Development Co. vs. WCC and Manila Railroad Co. vs. Vda. de Chavez, which emphasize the mandatory nature of timely reporting. On Issue 2: The Court found no error in the award being made without previous notice and hearing. Since the petitioner was deemed to have renounced its right to controvert the claim for compensation due to its failure to timely submit the Employer's Report of Accident, the validity of the respondents' claim was, in effect, admitted. In such circumstances, the Regional Labor Administrator was fully justified in proceeding directly to make the corresponding award without requiring a prior notice or hearing. The statutory renunciation of the right to controvert obviates the need for a formal contentious process. On Issue 3: The Court affirmed the implied presumption of Buen's death. Apart from the legal admission of death due to the uncontroverted claim, the death of Sofronio Buen was properly deduced from the circumstances of his disappearance. These circumstances included his disappearance from the petitioner's vessel while navigating on the high seas, the strong likelihood that he jumped or fell overboard while under the influence of liquor (creating circumstances unfavorable to an intelligent and effective effort on his part to save his life), the diligent but unsuccessful search for his body, the filing of a marine protest by the Master of the vessel, and his continued absence for almost four (4) years up to the time of the decision. These facts cumulatively provided a strong factual basis for inferring death. On Issue 4: The Court implicitly ruled that the filing of the Employer's Report of Accident or Sickness on January 30, 1962, did not satisfy the requirements of Section 1, Rule 14 of the Rules of the Workmen's Compensation Commission, specifically regarding timeliness. As established in the Court's reasoning on the first issue, the report was submitted 108 days after the accident, far beyond the prescribed 14-day or 10-day period. The crucial aspect of compliance is not merely filing the report, but filing it within the statutory period. The lack of any reasonable grounds provided by the petitioner to explain this significant delay further undermined its claim of satisfaction of the rules. On Issue 5: The Court held that the Workmen's Compensation Commission did not err in sending a copy of the award to petitioner's manager. At the time the award was made and notice thereof was served on February 24, 1962, petitioner's counsel had not yet formally entered his appearance in the case. Therefore, according to procedural rules, notice was properly served upon the petitioner itself, through its manager. There was no contravention of Section 2, Rule 27 of the Rules of Court because that rule applies when counsel has already made an appearance, which was not the case here. On Issue 6: The Court ruled that the reglementary period to seek a review of the award commenced to run from the date the petitioner itself received notice. Since petitioner's counsel had not yet entered an appearance at the time of the award, notice was properly served on the petitioner directly on February 24, 1962. Consequently, the 15-day period for seeking review, as prescribed by Rule 23, Section 1 of the Rules of the Commission, began to run from that date of personal receipt by the petitioner. The absence of counsel's appearance negates any argument that the period should commence from counsel's presumed or actual receipt of notice at a later date. On Issue 7: The Court concluded that the award had already become final and executory. Petitioner's motion to set aside the award was filed on March 16, 1962. However, the notice of the award was served upon the petitioner on February 24, 1962. The 15-day period for filing such a motion, as stipulated in Rule 23, Section 1 of the Rules of the Commission, had therefore already expired before March 16, 1962. Given the late filing of the motion to set aside, the award had effectively become final and executory, and the Commission was correct in affirming it.
Main Doctrine
Failure to file the Employer's Report of Accident within the statutory period, without justifiable grounds, constitutes a renunciation of the right to controvert the claim for compensation, rendering any subsequent award final and executory.