Pampanga Sugar Mills v. Galang Vda. de Espeleta
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a claim for death compensation benefits filed by Regina Galang Vda. de Espeleta, widow of a deceased employee, against her late husband's employer, Pampanga Sugar Mills. The claim was for compensation due to 'Cerebral Infraction due to Internal Hemorrhage caused by Hypertension,' which the widow asserted was work-related. The employer contested the claim on grounds of prescription, arguing the claim was filed significantly beyond the statutory period, and that the illness was not connected to the employee's work. 2. Procedural History: The claim for compensation was initially filed with a regional office of the Department of Labor, which rendered a decision in favor of the claimant widow. Pampanga Sugar Mills sought to have this decision reviewed but failed to file the petition for review within the reglementary period, citing excusable neglect by their messenger. Subsequently, a hearing referee of the Workmen's Compensation Commission issued a writ of execution to enforce the award. This led to the employer filing a petition for certiorari and mandamus with the Supreme Court to halt the execution. 3. The Petition: Pampanga Sugar Mills filed a petition for certiorari and mandamus with the Supreme Court, seeking to enjoin the Provincial Sheriff of Rizal from enforcing a writ of execution issued by a hearing referee of the Workmen's Compensation Commission. The petition argued that the award was granted despite valid defenses, specifically that the claim was filed out of the two-month reglementary period and that the employee's illness was not work-related. The employer also contended that their failure to file a timely petition for review was due to excusable neglect. The petition was filed under Rule 45 of the Rules of Court.
Issue(s)
Whether the failure to file a petition for review within the reglementary period due to alleged excusable neglect warrants the allowance of such review. Whether the defenses of prescription and lack of causal connection between the disease and work are valid when the employer failed to controvert the claim.
Ruling
The petition for certiorari and mandamus is denied, and the writ of preliminary injunction is lifted. The award of compensation is sustained.
Ratio Decidendi
On the issue of failure to file a petition for review due to excusable neglect: The Court found it unnecessary to pass on the plea for review based on excusable neglect. This is because the employer's failure to controvert the claim was deemed fatal to its defenses, including the defense of prescription. Therefore, even if the petition for review were allowed, the award would still have to be sustained due to the failure to controvert. On the issue of prescription and failure to controvert: The Court reiterated the established rule that the failure of an employer to controvert a claim for compensation under the Workmen's Compensation Act constitutes a renunciation of its right to challenge the claim. This failure is considered a constructive admission that the claim is compensable. Consequently, the employer cannot subsequently set up defenses such as prescription or lack of causal connection, as these defenses are deemed waived by operation of law. The Court cited several previous decisions to support this principle, emphasizing that such failure is fatal to the employer's defenses.
Main Doctrine
Failure to controvert a claim for compensation under the Workmen's Compensation Act constitutes a renunciation of the employer's right to challenge the claim, thereby rendering defenses such as prescription unavailing, even if the claim was filed out of the reglementary period.