Victorias Milling Co. v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Vicente del Rosario worked for Victorias Milling Co., Inc. from 1923 until his separation on August 25, 1955. His duties included operating river pumps, which required him to dive underwater to clean clogged pipes and screeners, often in cold water and during night shifts. He was hospitalized in September 1953 and again in August 1954 for pulmonary tuberculosis. He stopped working two weeks after his second hospitalization due to backache and was subsequently separated from the company due to pulmonary tuberculosis, receiving a gratuity of P2,717.34. Procedural History: On January 19, 1960, del Rosario filed a claim for compensation. The company filed its employer's report and other papers on March 7, 1960. The hearing officer found that the claimant's sickness was either aggravated by or resulted from his employment and ordered the company to pay compensation. The Workmen's Compensation Commission (WCC) affirmed this decision in toto and denied the company's motion for reconsideration. The Petition: The company appealed to the Supreme Court, contending that the WCC erred in entertaining the claim filed almost four and a half years after separation and in holding that the company's failure to file the employer's report and notice of controversion within the prescribed period constituted a statutory renunciation of defenses.
Issue(s)
Whether the claim for compensation filed almost four and a half years after separation from employment is barred by Section 24 of the Workmen's Compensation Act. Whether the company's failure to file its employer's report and notice of controversion within the ten-day period required by Section 45(2) of the Workmen's Compensation Act constitutes a statutory renunciation of its right to assert non-jurisdictional defenses. Whether pulmonary tuberculosis, in the context of the claimant's work conditions, can be considered an illness contracted during the course of employment, even if not an "occupational disease" in the strict sense.
Ruling
The Supreme Court affirmed the decision of the Workmen's Compensation Commission in toto, ordering the company to pay the claimant the adjudicated sums and costs.
Ratio Decidendi
On the timeliness of the claim: The Court reiterated its consistent ruling that failure to comply with the notice and filing requirements of Section 24 of the Workmen's Compensation Act is non-jurisdictional. Therefore, the claim filed almost four and a half years after separation was not barred on this ground. The Court emphasized that this doctrine has been repeatedly upheld in numerous previous cases, underscoring its established nature. On the failure to file the employer's report and notice of controversion: The Court held that the WCC did not err in concluding that the company's failure to file its employer's report and notice of controversion within the ten-day period mandated by Section 45(2) of the Workmen's Compensation Act amounted to a statutory renunciation of its right to assert non-jurisdictional defenses. The company filed these documents only after being prompted by the Regional Office, which was significantly beyond the prescribed period. On the nature of the sickness and its relation to employment: The Court affirmed the WCC's finding that the claimant's pulmonary tuberculosis was contracted during the period of his employment. It noted that the claimant underwent yearly physical examinations and was found fit for work until September 1953, when an X-ray revealed the disease. The Court found that the nature and conditions of his work, including diving in cold water, exposure to heat from pumps and roofing, frequent night shifts, and prior exposure in the Boiling House Department, likely lowered his body's resistance, making him susceptible to tuberculosis. Even if he had dormant tuberculosis or an arrested case, his work conditions could have reactivated it or constituted its original cause, entitling him to compensation.
Main Doctrine
Failure to comply with the requirements of Section 24 of the Workmen's Compensation Act regarding notice and filing of a claim within the prescribed period is non-jurisdictional. Furthermore, an employer's failure to file its employer's report and notice of controversion within the ten-day period required by Section 45(2) of the Act amounts to a statutory renunciation of its right to assert non-jurisdictional defenses.