Dinaro v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Lominog Dinaro, a clerical aide at the District Engineer's Office at Marawi City, filed a claim for compensation for Pulmonary Tuberculosis (PTB), moderately advanced, and rheumatism, general weakening of body, allegedly contracted or aggravated by his work since 1970. These illnesses forced him to stop working on May 31, 1973, and prevented his return. Procedural History: Petitioner submitted supporting documentary evidence, including a physician's report, his sick leave records, service record, and an X-ray finding of PTB. On July 9, 1975, the employer, through District Engineer Orlando Mancao, Sr., filed an Employer's Report expressly admitting the facts of the claim and stating they would not controvert it. Despite this, the Acting Chief Referee dismissed the case on August 15, 1975, for alleged failure to submit evidence of incapacitation. The Workmen's Compensation Commission affirmed the dismissal, deeming the physician's report unverified and insufficient, and citing a deadline for case disposition. The Petition: Petitioner sought review, arguing that the dismissal was erroneous given the employer's failure to controvert and express admission, and that the commission erred in dismissing his plea for an opportunity to submit additional evidence.
Issue(s)
Whether the Workmen's Compensation Commission erred in dismissing the petitioner's claim despite the employer's failure to controvert and express admission of the claim's compensability. Whether the commission erred in deeming the submitted medical evidence insufficient and in dismissing the petitioner's plea for an opportunity to submit additional evidence.
Ruling
The Supreme Court set aside the dismissal order of the respondent commission and ordered the respondent to pay the petitioner P6,000.00 as compensation, P600.00 as attorney's fees, and the statutory fees to the commission.
Ratio Decidendi
On the issue of dismissal despite non-controversion and express admission: The Court held that the respondent commission committed clear error in peremptorily dismissing the claim. Under Section 45 of the Workmen's Compensation Act, failure of the employer to controvert the claim constitutes a renunciation of the right to challenge it and a waiver of all non-jurisdictional defenses. This principle has been consistently applied in numerous cases. In the present case, the employer not only failed to controvert but expressly admitted the facts and details of the claim, stating it would not controvert the claim for compensation. This express admission, coupled with the failure to controvert, mandated the outright issuance of an award without the need for further hearing. The Court emphasized that when liability is admitted by the employer or in uncontroverted cases, an award should be issued forthwith as provided by Rule 9, Section 1 of the Workmen's Compensation Commission Rules. On the sufficiency of evidence and denial of opportunity to submit additional evidence: The Court found no basis for the commission's pronouncement of insufficient evidence. The petitioner had submitted ample documentary evidence, including a physician's report, sick leave records, service record, and X-ray findings, which supported his claim. The commission's imposition of a new requirement that the physician's report be verified, despite the claim being uncontroverted and expressly admitted, was deemed an error. Furthermore, the commission's summary rejection of the petitioner's plea for an opportunity to submit additional medical evidence as "dilatory tactics" was also patent error, especially considering the petitioner's urgent need for the benefits. The commission's approaching deadline for case disposition did not justify denying the claimant a fair opportunity to present his case, particularly when the employer had already admitted liability.
Main Doctrine
Failure of an employer to controvert a claim for compensation, or an express admission of the claim's compensability, constitutes a renunciation of the right to challenge the claim and a waiver of all non-jurisdictional defenses, mandating the outright issuance of an award without the need for further hearing.