Galang v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Federico Manligas, an employee of petitioner Emilio L. Galang, died when the jeep he was driving collided with a parked truck. The incident occurred while Manligas was driving the jeep very fast in the early morning of November 30, 1967. The truck had previously been involved in another accident and was being investigated by local policemen at the scene. Procedural History: Respondent-claimant Juanita A. Vda. de Manligas filed a claim for compensation on February 9, 1968. Petitioner Galang answered on February 26, 1968, denying liability on grounds that the deceased used the company jeep without permission and was guilty of notorious negligence. The Commission overruled the denial, holding that petitioner's failure to controvert the claim within ten days from November 30, 1967, barred the defense, and that shouldering burial expenses and making advance payments constituted admission of liability. The Chairman's decision affirming the award was served on petitioner on June 2, 1971. Petitioner filed a petition for review on June 14, 1971, alleging lack of causal connection, notorious negligence, timely controversion, and that payments were from group insurance. The Commission denied this petition for being filed out of time (12 days instead of 10). The Petition: Petitioner filed a motion for reconsideration, arguing that June 12, 1971 (the 10th day) was a holiday (Independence Day) and June 13, 1971, was a Sunday, thus his petition filed on June 14, 1971, was within the reglementary period under Section 31 of the Revised Administrative Code. The Commission denied the motion, stating that petitioner could have used the postal service, which was allegedly open.
Issue(s)
Whether the petition for review filed on June 14, 1971, was filed within the reglementary period. Whether the petitioner failed to controvert the claim within the period prescribed by law, thereby waiving his right to interpose defenses. Whether the death of Federico Manligas was compensable under the Workmen's Compensation Act.
Ruling
The petition is denied. The decision of the Workmen's Compensation Commission is declared immediately executory. Petitioner shall pay the costs.
Ratio Decidendi
On the timeliness of the petition for review: The Court found the Commission's resolution erroneous. Section 31 of the Revised Administrative Code clearly states that where the last day for doing any act falls on a holiday, the act may be done on the next succeeding business day. The Commission's argument that the petitioner could have used the postal service, even if true, overlooks the principle that when the office where the pleading is to be filed is closed for business due to a holiday, all other offices acting as agents for the Commission are also deemed closed for that specific business. This interpretation deviates from the general understanding and practice of applying Section 31. Therefore, the petition filed on June 14, 1971, should have been considered timely. On the failure to controvert the claim: While the Court agreed that the petition for review was filed on time, it felt that substantial justice required the denial of the petition on the merits. The Court noted that the petitioner failed to file the employer's report required by Sections 37 and 45 of the Compensation Act within the prescribed ten-day period. The incident occurred on November 30, 1967, and the petitioner was notified on the same day, yet he did not file his controversion until February 26, 1968, four days after the formal claim was filed. This failure to controvert within the statutory period, as per Section 45 of the Act, constitutes a renunciation of the employer's right to controvert. On the compensability of the death: Applying the ruling in Vda. de Calado v. Workmen's Compensation Commission, the Court held that the employer's strict compliance with filing the notice of injury or death and formally controverting liability within the fixed periods is decisive. The absence of a timely controversion means the employer has renounced the right to controvert. Given the undisputed facts, including the failure to file the employer's report and controvert the claim within the prescribed periods, there was no legal defense for the employer to deny liability. Remanding the case would be an idle ceremony, as a different decision could not be correctly rendered by the Commission.
Main Doctrine
When the last day for filing a pleading falls on a holiday or weekend, the act may be done on the next succeeding business day, and this rule applies even if postal offices are open, as the Commission itself is deemed closed for business.