Apolega v. Hizon
REITERATIONFacts
The Antecedents: Melanio Hizon filed a claim for compensation for an injury sustained while employed by Proceso Apolega. Apolega failed to submit the required employer's reports. An award was issued for medical expenses and compensation benefits. Melanio Hizon later died from complications of the injury, and his widow, Perseveranda Hizon, filed a death compensation claim on behalf of herself and their minor children. This claim also went uncontroverted, and a renewed award was issued for medical expenses, burial expenses, compensation benefits, and fees. Procedural History: Following the initial award for Melanio Hizon's injury, Apolega failed to file required reports. After Melanio Hizon's death, a death compensation claim was filed by his widow, which also went uncontroverted, leading to a renewed award. Apolega filed a motion for extension to file a motion to vacate and dismiss, but failed to submit the pleading within the granted period. Consequently, the award was declared final and executory, and the case was elevated to the Workmen's Compensation Commission. The Commission affirmed the award as final and executory and remanded the case for appropriate action. A writ of execution was subsequently issued against Apolega's properties. The Petition: Proceso Apolega filed a petition for certiorari and prohibition with preliminary injunction with the Supreme Court, averring that the claim was time-barred, that the hearing officer's failure to set a hearing and provide notice constituted grave abuse of discretion, and that Section 17 of Republic Act 4119, which grants authority to issue writs of execution to the Commission and its officials, is unconstitutional. Apolega argued he was not given an opportunity to present evidence and that the proceedings were void. The Supreme Court considered the partial payment of benefits, which rendered the filing within the statutory period unnecessary, and upheld the constitutionality of Republic Act 4119, finding the writ of execution valid.
Issue(s)
Whether the claim for compensation was time-barred. Whether the failure to set the case for hearing and provide notice to the petitioner constituted grave abuse of discretion or excess of jurisdiction. Whether Section 17 of Republic Act 4119, granting the Commission and its deputized officials the authority to issue writs of execution, is unconstitutional.
Ruling
The petition is dismissed, and the writ of preliminary injunction is dissolved.
Ratio Decidendi
On the issue of the claim being time-barred: The Court held that the failure of the employer to controvert the claim, as required by Section 45 of the Workmen's Compensation Act, constituted a waiver of the right to present evidence. This allowed the hearing officer to make an award without the necessity of a formal hearing, treating the claim as uncontested. Furthermore, the Court noted that partial payments of benefits made by the employer, even before the claim was filed, rendered the filing within the statutory period unnecessary, pursuant to Section 24 of the Workmen's Compensation Act as amended by Republic Act No. 4119. The Court cited Rio y Cia. vs. WCC, et al. to support the proposition that a non-jurisdictional delay in filing does not bar proceedings if the employer suffers no prejudice. On the issue of lack of notice and hearing: The Court found that the allegation of lack of notice and hearing could not be sustained because the petitioner failed to controvert the claims. This failure resulted in the waiver of his right to present evidence. Consequently, the proceedings could validly result in an award without a formal hearing. The Court emphasized that the petitioner was given an opportunity to be heard when he was granted an extension to file a motion to vacate the award and dismiss the case, an opportunity he failed to utilize. On the constitutionality of Section 17 of Republic Act 4119: The Court affirmed the constitutionality of Section 17 of Republic Act 4119, which amended Section 51 of the Workmen's Compensation Act and vested the power to enforce awards through writs of execution in the Workmen's Compensation Commission and its deputized officials. The Court traced the evolution of this power, noting that while previous reorganization plans were nullified for lack of legislative authority, R.A. 4119 expressly granted this power. The Court reasoned that while execution is procedural, Congress has the constitutional authority to legislate on matters of pleading, practice, and procedure. The Court distinguished this from prior enactments and cited Lo Chi, et al. vs. De Leon, et al., which impliedly upheld the constitutionality of R.A. 4119 by stating that a writ issued before its effectivity was void.
Main Doctrine
Failure of an employer to controvert a claim for compensation under the Workmen's Compensation Act results in the waiver of the right to present evidence, allowing the hearing officer to issue an award without a formal hearing. Furthermore, partial payment of benefits renders the claim's filing within the statutory period unnecessary, and the authority of the Workmen's Compensation Commission and its deputized officials to issue writs of execution, as granted by R.A. 4119, is constitutional.