National Development Company v. Rongavilla
REITERATIONFacts
The Antecedents: Respondent Roberta Rongavilla was employed by petitioner National Development Company (NDC) from October 23, 1946, until June 11, 1951, when she was separated due to ill health. Her work as a pirm winder involved operating a machine with twenty spindles, requiring her to be on her feet most of the time to connect broken yarn and restart the machine. She also had to transport yarn supplies and finished products, sometimes pushing a loaded cab herself. On October 16, 1950, she was diagnosed with minimal pulmonary tuberculosis. After a three-month rest advised by the NDC physician, she returned to work. By March 19, 1951, her condition had progressed to a moderately advanced stage, prompting further treatment. Procedural History: On May 31, 1960, nearly nine years after her separation, Rongavilla filed a claim for disability compensation for pulmonary tuberculosis. The Regional Office No. 4 awarded compensation. The NDC petitioned for review with the Workmen's Compensation Commission (WCC), which upheld the award, ruling that the acceleration of a sickness due to employment is a ground for compensation. The WCC ordered NDC to pay P3,000.00 in lump sum, attorney's fees, and Workmen's Compensation Fund fees. NDC's motion for reconsideration was denied. The Petition: The NDC appealed to the Supreme Court, arguing that the WCC erred in holding the illness and its aggravation compensable prior to the amendment of Republic Act 772, and that the WCC lacked jurisdiction due to the late filing of the claim under Section 24 of Act 3428.
Issue(s)
Whether the illness of the employee due to tuberculosis and the aggravation of that illness, which occurred before the enactment of Republic Act 772, is a ground for disability compensation. Whether the Workmen's Compensation Commission had jurisdiction to entertain the employee's claim for compensation despite the claim not being filed in accordance with Section 24 of Act 3428.
Ruling
The petition is dismissed, and the decision and resolution of the respondent Workmen's Compensation Commission are affirmed.
Ratio Decidendi
On the compensability of illness and aggravation prior to RA 772: The contention of the NDC is without merit. Even before Republic Act 772 took effect on June 20, 1952, Section 2 of Act 3428 already provided for compensation if an employee contracted "any illness directly caused by such employment, or the result of the nature of such employment." The WCC found that Rongavilla contracted tuberculosis because of the nature of her employment, evidenced by the rapid acceleration of her illness after returning to work, her physically demanding tasks, and the debilitating effect of night shifts. The Court reiterated the ruling in Blue Bar Coconut Company, et al. vs. Joaquin Boo and Manila Railroad Company vs. Daniel Perez, stating that the insertion of "tuberculosis" and "aggravated by" in Section 2 by RA 772 was merely for clarification, as the original Act already covered illnesses resulting from the nature of employment. Therefore, the illness was compensable even prior to the amendment. On the jurisdiction of the WCC despite late filing: The NDC's argument that the WCC lacked jurisdiction due to the late filing of the claim under Section 24 of Act 3428 is also without merit. It is a well-settled rule that failure to comply with the notice and filing requirements of Section 24 is non-jurisdictional. Moreover, failure to give notice is not a bar if the employer had knowledge of the injury or sickness, or did not suffer by the delay. Crucially, if the employer fails to controvert the claim within the periods prescribed in Section 45 of Act 3428, the WCC can proceed to decide the claim. In this case, the NDC had full knowledge of Rongavilla's illness prior to her discharge but failed to file the employer's report or controvert the claim within the statutory period. This failure constituted a renunciation of its right to controvert, precluding it from later contesting the claim based on the employee's non-compliance with Section 24. The Court also noted that the liability under the Workmen's Compensation Act is a legal obligation enforceable within ten years under Article 1144(2) of the Civil Code, making the filing of the claim almost nine years after disability not a bar.
Main Doctrine
The Workmen's Compensation Commission has jurisdiction to entertain a claim for compensation even if filed beyond the prescribed period, provided the employer fails to controvert the claim within the statutory period, thereby renouncing its right to controvert. Furthermore, an illness contracted during employment, even if not explicitly listed as compensable at the time of contraction, is compensable if it is shown to be caused by or is the result of the nature of the employment, especially if aggravated by said employment.