Surigao Consolidated Mining Co. v. Tuibuen
REITERATIONFacts
1. The Antecedents: Respondent Cleto Tuibuen was employed by petitioner Surigao Consolidated Mining Company, Inc. as a rustler jigger. On March 6, 1954, while working, Tuibuen was struck by a wooden splinter during a blast, resulting in impaired hearing. The accident was attributed to the failure of petitioner's repairmen to properly guard blasting areas. Despite his injury, Tuibuen continued working until May 18, 1954, when he was laid off due to his hearing impairment. 2. Procedural History: Tuibuen filed a claim for compensation with the Department of Labor in 2060, which was later transferred and subsequently dismissed without prejudice. He refiled a claim in Manila in May 1964. Petitioner moved to dismiss the claim, arguing it was filed out of time and prescribed. The acting referee dismissed the claim, but this decision was reversed by the Workmen's Compensation Commission (WCC) on March 16, 1966. A motion for reconsideration by the petitioner was denied by the WCC en banc on April 15, 1966. 3. The Petition: Petitioner seeks review of the WCC's decision and resolution, primarily arguing that Tuibuen's claim was filed too late and that proper notice of the accident was not given as required by Section 24 of Act 3428. Petitioner contends that compliance with these requirements is mandatory. The petition is filed under Rule 45 of the Rules of Court, seeking to overturn the WCC's finding that the delay in filing was excusable due to the employer's failure to file a timely controversion as mandated by Section 45 of the Act.
Issue(s)
Whether the claim for compensation was filed within the statutory period. Whether the failure to give notice of the accident and the delay in filing the claim barred respondent's right to compensation.
Ruling
The petition for review was dismissed, and the decision and resolution of the respondent Workmen's Compensation Commission were affirmed. Petitioner was ordered to pay respondent the awarded compensation, attorney's fees, and other fees.
Ratio Decidendi
On Issue 1: The Supreme Court held that the claim for compensation was not barred by prescription. The Court reiterated its established jurisprudence that the failure of an employer to file its controversion to an employee's claim within the time fixed by Section 45 of the Workmen's Compensation Act is a waiver of its right to controvert the claim. Despite the claim being filed six years after the accident, the Commission found that the petitioner failed to file its controversion within the statutory period, despite having knowledge of the accident since March 6, 1954. This failure to controvert meant the Commission could still proceed to determine and decide the claim for compensation. Furthermore, the Court clarified that the liability of an employer to pay compensation is a legal obligation enforceable within ten years from the time the right of action accrues, as provided by Article 1144(2) of the Civil Code, especially when the employer has not controverted the claim. On Issue 2: The Court affirmed that the failure to give notice of the accident or injury, or the delay in filing the claim, does not necessarily bar compensation. This is because such requirements under Section 24 of Act 3428 are considered non-jurisdictional. The Court has consistently ruled that if the employer, its agent, or representative had knowledge of the injury, sickness, or death, or if the employer did not suffer by such delay or failure, the claim can still prosper. In this case, the petitioner had knowledge of the accident through its safety engineer and allowed the respondent to continue working despite his condition. The petitioner also failed to serve notice of the injury as required by Section 37 of Act 3428. By failing to file a timely controversion, the petitioner was deemed to have renounced its right to contest the compensability of the respondent's disability on the grounds of lack of notice or delayed filing.
Main Doctrine
The Supreme Court reiterated that non-jurisdictional defects in filing a claim for compensation, such as failure to give notice of injury or filing beyond the prescribed period, are deemed waived if the employer fails to file a timely controversion. This failure to controvert, especially when the employer has knowledge of the injury, estops the employer from later questioning the claim on procedural grounds. Furthermore, the Court clarified that the prescriptive period for enforcing statutory obligations like workmen's compensation is ten years under Article 1144(2) of the Civil Code, not the period specified in the Workmen's Compensation Act itself, when the employer has not controverted the claim.