Blanco v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: On June 18, 1956, a six-by-six truck loaded with logs and six men overturned in Masinloc, Zambales. Four men, including Tomas Dragon and Diomedes Basa, died. The truck was owned by petitioner Crispiniano Blanco, who was engaged in the logging business. Dragon and Basa were employed by Blanco as woodcutters and were on board the truck by his orders to assist in log delivery. Dragon was survived by his parents, Sebastian and Bonifacia Dragon, who were wholly dependent on him. Basa was survived by his wife, Erlinda Domulot, and daughter, Remedios Basa, who were also wholly dependent on him. Procedural History: Following the deaths, petitioner Blanco paid P500.00 to Erlinda Domulot and Sebastian Dragon, allegedly as consideration for the dismissal of charges against the driver, Amador Macaspac. Sebastian Dragon and Erlinda Domulot filed claims for death compensation. Petitioner denied liability, asserting no employer-employee relationship existed and that he was unaware the deceased were on the truck. Hearing Officers denied both claims, finding no employer-employee relationship. The claimants appealed to the Workmen's Compensation Commission (WCC), which set aside the decisions and awarded compensation. Petitioner's motion for reconsideration was denied. The Petition: Petitioner filed a Petition for Certiorari with the Supreme Court, raising several issues regarding the WCC's jurisdiction, prescription of claims, admission of hearsay evidence, consideration of an amicable settlement as proof of employment, and the finding of an employer-employee relationship without sufficient evidence.
Issue(s)
Whether the Workmen's Compensation Commission lost jurisdiction to decide the case following the alleged withdrawal of the petitions for review by the claimants. Whether the claims for death compensation had prescribed and whether the petitioner waived this defense. Whether the petitioner's failure to controvert the claim under Section 45 of the Workmen's Compensation Act barred him from raising defenses. Whether the Commission committed grave abuse of discretion in admitting the affidavit of the driver as evidence to prove the employer-employee relationship.
Ruling
The Supreme Court affirmed the decision of the Workmen's Compensation Commission, upholding the award of death benefits and burial expenses to the claimants. The Court found no merit in the petitioner's contentions regarding the WCC's jurisdiction, prescription of claims, and the admission of evidence. The Court ruled that the alleged withdrawal of petitions was not sufficiently established and that the WCC correctly considered the evidence presented, including testimonies and payments made, to establish the employer-employee relationship.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the Commission did not lose jurisdiction because the alleged withdrawal of the petitions for review was not sufficiently established. The claimant denied the intent to withdraw, asserting in an affidavit that his signature was obtained through fraud and misrepresentation by the petitioner. The claimant believed he was only signing a certificate for the dismissal of the criminal case against the driver. The Court held that the Commission had the inherent authority and jurisdiction to determine the validity of the withdrawal and to investigate allegations of fraud. Since the Commission found that the claimant never intended to abandon the compensation claim, it correctly proceeded to resolve the case on its merits. On Issue 2: The Court held that the contention regarding prescription was untenable because it was raised for the first time on appeal to the Commission. Prevailing jurisprudence, including Martha Lumber Mill vs. Lagradante, dictates that the defense of prescription is waived if the employer fails to plead it before or during the trial. The Court emphasized that prescription is a matter of defense that must be timely invoked to afford the adverse party an opportunity to present evidence in rebuttal. By failing to raise it at the earliest opportunity, the petitioner is presumed to have waived said defense. Therefore, the Commission properly disregarded the belated claim of prescription. On Issue 3: The petitioner is barred from invoking the defense of prescription because he failed to controvert the claims within the period provided by Section 45 of the Workmen's Compensation Act. The law requires an employer to notify the Commission of their intent to contest the right to compensation; failure to do so results in the loss of the right to challenge the claim. Petitioner’s argument that he could not controvert due to a denial of the employment relationship was rejected. The Court noted that an employer must choose their defenses wisely, and by standing on the defense of non-employment while failing to raise others like prescription, they are deemed to have waived the latter. The failure to controvert makes the claim compensable as a matter of law. On Issue 4: The admission of the driver's affidavit did not constitute a grave abuse of discretion as it was merely corroborative of other substantial evidence. Administrative agencies like the WCC are not strictly bound by technical rules of evidence, and the hearsay rule is not applied with the same rigidity as in judicial proceedings. The record contained sufficient competent evidence to establish the employer-employee relationship, including Blanco's ownership of the truck and the payment of P500.00 settlements to the heirs. Furthermore, testimonies from several former wood cutters of the petitioner clearly identified him as the employer of the deceased wood cutters. Thus, even if the affidavit were disregarded, the Commission's findings of fact were supported by substantial evidence.
Main Doctrine
The employer's failure to controvert a claim for compensation within the period provided by law, or the failure to raise the defense of prescription before or during the trial, constitutes a waiver of such defenses, entitling the claimant to compensation as a matter of law. Furthermore, an employer cannot invoke the defense of prescription if they failed to controvert the claim within the statutory period, as this failure is deemed a waiver of the right to do so.