Victorias Milling Co. v. Dadivas
REITERATIONFacts
The Antecedents: Rufino Pineda, a former laborer of Victorias Milling Co., Inc. (petitioner), filed a claim for compensation on October 18, 1961, alleging he contracted pulmonary tuberculosis in the course of his employment and was discharged in November 1952 due to this illness. Pineda claimed a daily wage of P4.00 as a piece worker. Procedural History: Petitioner moved to dismiss Pineda's claim, arguing it was filed beyond the two-month period prescribed by Section 24 of the Workmen's Compensation Act. Respondent Acting Referee Bertito D. Dadivas denied this motion. Petitioner then filed a petition for prohibition and preliminary injunction with the Court of First Instance (CFI) of Negros Occidental to stop the proceedings, asserting lack of jurisdiction due to the late filing. Pineda intervened, asserting the Workmen's Compensation Commission's exclusive jurisdiction and petitioner's failure to seasonably controvert the claim. The CFI dismissed petitioner's action, sustaining Dadivas' contention. Hence, this appeal. The Petition: Petitioner appealed the CFI's dismissal, seeking to restrain the Acting Referee from proceeding with the claim due to its alleged late filing, which petitioner argued divested the respondent of jurisdiction.
Issue(s)
Whether the Workmen's Compensation Commission has jurisdiction to hear and decide Pineda's claim for compensation despite its filing beyond the prescribed two-month period. Whether the late filing of a claim for compensation is a jurisdictional defect or a mere defense.
Ruling
The Supreme Court affirmed the order of the lower court dismissing the petition for prohibition and preliminary injunction, upholding the jurisdiction of the respondent Acting Referee to hear and decide the claim for compensation.
Ratio Decidendi
On the jurisdiction to hear and decide the claim despite late filing: The Court held that the Workmen's Compensation Act requires compliance with the two-month period for filing a claim to ensure the claim "prospers," meaning it leads to a favorable decision. However, this compliance is not essential to the jurisdiction of the Commission to entertain the claim. The Court reiterated its consistent view, supported by jurisprudence, that the late filing of a claim for compensation is not a jurisdictional defect but rather a matter of defense that the employer may raise. Therefore, the respondent Acting Referee did not err in denying the motion to dismiss based on the alleged late filing. On whether late filing is jurisdictional or a defense: The Court clarified that the prevailing view is that the timeliness of notice and claim under Section 24 of the Workmen's Compensation Act is not jurisdictional. This defense, like others, can be waived by the employer or insurer if not seasonably raised. The Court cited legal scholars Horovitz and Larson, who state that the majority rule considers strict compliance with notice and claim requirements waivable. The Court's own jurisprudence has also adopted this stance, emphasizing that failure of the employer to file a timely controversion under Section 45 of the law bars all defenses, including the defense of late filing by the employee. This is because Section 45 mandates that failure to controvert within the prescribed period constitutes a renunciation of the employer's right to controvert the claim, unless reasonable grounds for the delay are shown.
Main Doctrine
The late filing of a claim for compensation under the Workmen's Compensation Act is not jurisdictional but a mere defense that can be waived by the employer, especially if the employer fails to file a timely controversion of the claim.