Northwest Orient Airlines v. Mateu
REITERATIONFacts
The Antecedents: Louise Mateu, an employee of Northwest Orient Airlines, Inc., filed a claim for compensation due to injuries sustained from a car accident in 1948 while stationed in Tokyo, Japan, and a subsequent incident in 1957 when the aircraft she was on experienced a sudden loss of altitude between Okinawa and Tokyo. These incidents caused her right shoulder and arm to bother her, leading to temporary total disability for labor, particularly a period of disablement from September 8, 1964, to November 1, 1964, diagnosed as Biceps tendonitis, right, and Fibrositis, right shoulder girdle musculature. Procedural History: Claimant Louise Mateu filed her Notice of Injury or Sickness and Claim for Compensation on January 27, 1965, along with supporting medical reports. The Workmen's Compensation Commission's regional office furnished Northwest Orient Airlines, Inc. with the notice. While the employer's insurer initially reserved the right to controvert the claim pending investigation, this reservation was made out of time, and no further action was taken by the employer to controvert the claim. The referee issued an award in favor of the claimant, which was affirmed by the Workmen's Compensation Commission. The Petition: Northwest Orient Airlines, Inc. filed a petition for review of the Workmen's Compensation Commission's decision. The petitioner raised several assignments of error, including disputing the finding of fact regarding the controversion of the claim, alleging a denial of due process due to the failure to accord them a day in court, and objecting to the late filing of the claim. The petition essentially sought to reverse the Commission's decision based on these arguments, but the Supreme Court found no justification to overturn the established doctrine on the adverse consequences of non-controversion by the employer.
Issue(s)
Whether the respondent Workmen's Compensation Commission erred in finding that the petitioner failed to controvert the claim within the statutory period. Whether the petitioner was denied due process by the alleged failure to accord it its day in court. Whether the claim was filed out of time and if such delay is fatal to its success.
Ruling
The decision of the respondent Workmen's Compensation Commission affirming the award of its chief referee in favor of respondent Louise Mateu is affirmed. Costs are against petitioner Northwest Orient Airlines, Inc.
Ratio Decidendi
On the issue of failure to controvert: The Court reiterated the controlling doctrine that non-controversion by the employer has adverse consequences. The reservation of the right to controvert made by the insurer on behalf of the petitioner was out of time, and no further action was taken. Under the circumstances, the respondent Commission correctly viewed that there was an admission that the injury was work-connected due to the failure to controvert. Findings of fact based on substantial evidence of record are binding and conclusive upon the Supreme Court. On the issue of due process: The Court reiterated that in the absence of controversion, the due process argument is unlikely to prevail. Citing previous rulings, the Court stated that failure to file an answer to the claim within ten (10) days from notice means the employer is deemed to have renounced its right to controvert the claim. Consequently, the claim is deemed admitted, and the employer has no further right to demand a day in court. On the issue of late filing of the claim: The Court held that the objection to the late filing of the claim is not persuasive. Failure to controvert amounts to a waiver or renunciation of the defense that the claim was not filed within the statutory period. The failure to controvert is fatal to the defense of the claim having been filed out of time. Furthermore, the Court noted the trend of its decisions to consider delay in filing as a non-jurisdictional defect, unless prejudice to the employer is shown, aligning with the need to protect the workman.
Main Doctrine
Failure to controvert a claim for workmen's compensation within the statutory period constitutes a waiver of the employer's right to raise defenses, including the defense of late filing, and is deemed an admission of the claim's validity.