Insular Lumber Company v. Workmen's Compensation Commission
REITERATIONFacts
1. The Antecedents: Jose Quinto was employed by Insular Lumber Company from 1925 until May 10, 1952, holding positions including moulder and capataz. On July 27, 1950, a chest X-ray revealed Quinto had far-advanced pulmonary tuberculosis, leading to hospitalization and treatment by the company physician. He continued working until his discharge on May 10, 1952, due to persistent illness confirmed by subsequent X-rays. 2. Procedural History: On April 21, 1960, Jose Quinto filed a claim for compensation benefits. Insular Lumber Company controverted the claim, asserting it was not employment-related, aggravated by employment, or a result of the nature of employment, and that it was filed beyond the statutory period. A hearing officer awarded Quinto P4,000.00 in compensation. The Workmen's Compensation Commission affirmed the decision but reduced the award to P3,000.00, the maximum under the applicable law at the time of separation. 3. The Petition: Insular Lumber Company petitioned for review, not disputing the compensability of Quinto's illness, but arguing the claim was untimely filed and had been waived or extinguished. The company contended Quinto's claim was filed beyond the two-month period prescribed by Section 24 of the Compensation Act. Furthermore, the company argued Quinto waived his claim by signing a cash voucher on May 10, 1952, acknowledging no further claims against the petitioner.
Issue(s)
Whether the claim for compensation was filed out of time. Whether the petitioner waived its right to controvert the claim. Whether the respondent waived or renounced his claim for compensation.
Ruling
The decision of the Workmen's Compensation Commission is affirmed. The petitioner is ordered to pay the respondent P3,000.00 as compensation benefits.
Ratio Decidendi
On the issue of the claim being filed out of time: The claim was filed beyond the two-month period prescribed by Section 24 of the Compensation Act, as the respondent's affliction was known in July 1950 and the claim was filed on April 21, 1960. However, delay does not bar proceedings if the employer had knowledge of the injury or sickness, or did not suffer by the delay. The purpose of the notice requirement is to give the employer an opportunity to investigate and controvert the claim. In this case, the employer had such opportunity, rendering the delay immaterial as per Section 24 of the Act. The Supreme Court reiterated the principle that failure or delay in giving notice is not a bar if the employer had knowledge or did not suffer by the delay, citing Vda. de Calado vs. Workmen's Compensation Commission. On the issue of waiver of the right to controvert: The petitioner failed to controvert the right to compensation within the period prescribed by Section 45 of the Compensation Act, which requires controversion within ten days from the employer's knowledge of the disability. The petitioner's letter-controversion dated July 20, 1960, was filed long after this period. Such failure to controvert within the statutory period constitutes a waiver of the right to controvert, as established in jurisprudence, specifically citing Pioneer Ceramics, Inc. vs. Eliseo O. Samia, et al.. On the issue of waiver of the claim: The petitioner's contention that the respondent waived his claim by signing a cash voucher on May 10, 1952, is without merit. The voucher stated he had no further claims against the petitioner. However, Section 7 of the Compensation Act explicitly declares null and void any contract, regulation, or device intended to exempt the employer from liability created by the Act. Therefore, such a waiver is legally ineffective.
Main Doctrine
Delay in filing a claim for compensation does not bar the proceeding if the employer had knowledge of the injury or sickness, or did not suffer by such delay, and failure to controvert the claim within the statutory period constitutes a waiver of the right to controvert. Furthermore, any contract or device intended to exempt the employer from liability under the Compensation Act is null and void.