Development Bank v. Workmen's Compensation Commission
REITERATIONFacts
1. The Antecedents: Wilfredo P. Britanico, an employee of the Development Bank of the Philippines (DBP) as a records and mailing clerk, died on October 29, 1967, due to massive pulmonary hemorrhage, pulmonary Koch's, and hypertension. His widow, Melchora C. Vda. de Britanico, filed a claim for death benefits on behalf of herself and their eight minor children. 2. Procedural History: The claim was filed on December 5, 1967. The DBP received notice and forms on December 18, 1967, and submitted an employer's report on January 4, 1968, admitting knowledge of the illness and death. The DBP's motion to dismiss, arguing it was not covered by the Workmen's Compensation Commission, was denied on March 11, 1968. A motion for reconsideration was also denied on March 19, 1968. The DBP then filed a petition for prohibition with the Supreme Court, which was dismissed on August 30, 1968, affirming DBP as a government instrumentality. Subsequently, the claimant moved to declare the claim uncontroverted due to the DBP's failure to file a timely controversion. The WCU Referee declared the claim uncontroverted and ruled in favor of the claimant on September 18, 1968. The DBP's motion for reconsideration and reinstatement of its right to controvert was denied on October 31, 1968, and the case was elevated to the Workmen's Compensation Commission (WCC). The WCC rendered its decision on January 22, 1969, affirming the award of death benefits, though with a corrected computation. A motion for reconsideration by the DBP was denied on February 12, 1969. 3. The Petition: The Development Bank of the Philippines seeks to annul the WCC's decision, requesting the case be remanded for a new hearing on the merits and for the reinstatement of its right to controvert the claim. The DBP argues it was deprived of its right to be heard by the refusal to grant a motion for postponement and that the WCC erred in not reinstating its right to controvert the claim. The petition highlights the DBP's late filing of its employer's report and controversion, and its prior unsuccessful petition for prohibition to the Supreme Court.
Issue(s)
Whether the WCU Referee abused his discretion in proceeding with the hearing on April 8, 1968, despite DBP's motion for postponement. Whether the WCC erred in not reinstating DBP's right to controvert the claim.
Ruling
The Supreme Court affirmed the decision of the Workmen's Compensation Commission dated January 22, 1969, and dismissed the petition for review. The Court held that DBP was not deprived of its right to be heard and that the WCC did not err in refusing to reinstate DBP's right to controvert the claim.
Ratio Decidendi
On the issue of denial of the right to be heard: The respondent WCU Referee did not abuse his discretion in proceeding with the hearing on April 8, 1968, as no restraining order or writ of preliminary injunction was issued by the Supreme Court enjoining the hearing during the pendency of DBP's petition for prohibition. DBP had ample time to prepare for the hearing, having had knowledge of the ailment and death of the employee for several months. The motion for postponement was considered purely dilatory. The Court noted that DBP could have raised the jurisdictional issue at the trial and on appeal instead of filing a prohibition petition first. The payment of hospital bills by DBP was also considered an admission of liability. On the issue of reinstating the right to controvert: The WCC and WCU Referee did not err in rejecting DBP's motion for reinstatement of its right to controvert. Section 45 of the Workmen's Compensation Act mandates that failure to controvert the claim within the prescribed period constitutes a renunciation of the right to controvert, unless reasonable grounds for the failure are submitted. DBP conceded its failure to controvert within the period. The filing of an urgent motion for reconsideration of the Supreme Court's dismissal of its prohibition petition was not a reasonable ground to withhold the decision. Furthermore, DBP's pretension that it believed the illness was ordinary nose bleeding was not credible, given the medical records and its proximity to the hospitals. The Court reiterated that failure to submit the employer's report of illness or death as soon as possible, as required by Section 37 of the Act, also amounts to a waiver of the right to controvert.
Main Doctrine
Failure to controvert a claim for death benefits within the period prescribed by Section 45 of the Workmen's Compensation Act, as amended, constitutes a renunciation of the employer's right to controvert the claim and all defenses, including the defense that the claim is not compensable. The employer's right to controvert may only be reinstated upon submission of reasonable grounds for the failure to make the necessary reports.