Contratista v. Artex Development Co.
REITERATIONFacts
The Antecedents: Eladio Contratista filed a claim for compensation for the death of his son, Alexander Contratista, who was allegedly stabbed inside the ARTEX compound on July 10, 1968, by Gervacio Antojado, a helper of Anastacia Albino, who managed a store-boarding house within the compound. Alexander died shortly thereafter while being brought to the municipal hall by Malabon policemen. Procedural History: The Acting Referee initially awarded death and related benefits. ARTEX moved for reconsideration, and the case was reopened for ARTEX's evidence, which ARTEX failed to present. The Acting Referee revived the original decision. The Workmen's Compensation Commission (WCC) en banc set aside the decision of its member, absolving ARTEX from liability, relying on a police report submitted by ARTEX with its motion for reconsideration. The Petition: Eladio Contratista sought review of the WCC en banc's resolution, arguing that ARTEX failed to file a notice of appeal, that ARTEX waived its right to controvert the claim due to late filing, and that the WCC en banc improperly admitted and relied upon the police report.
Issue(s)
Whether the claimant failed to perfect his appeal to the Supreme Court. Whether ARTEX waived its right to controvert the claim for compensation due to its failure to file the required notice within the period prescribed by law. Whether the Workmen's Compensation Commission en banc erred in admitting and giving probative value to the police report submitted belatedly by ARTEX. Whether Alexander Contratista's death arose out of and in the course of his employment.
Ruling
The Supreme Court set aside the resolution of the Workmen's Compensation Commission en banc, ordered ARTEX Development Co., Inc. to pay Eladio Contratista death and burial expenses, attorney's fees, and ordered payment to the Workmen's Compensation Fund. The Court directed the Clerk of Court to furnish a copy of the decision and the Malabon police report to the Secretary of Justice for appropriate action.
Ratio Decidendi
On the failure to file a notice of appeal: The Court held that the contention that the claimant failed to file a notice of appeal with the Workmen's Compensation Commission, rendering the decision final and executory, was without merit. Citing Vargas vs. Philippine American Embroideries, Inc., the Court clarified that the current Rules of Court do not explicitly require a notice of appeal for the perfection of an appeal, unlike the former rules, thus precluding the Court from taking cognizance of the case. On the waiver of the right to controvert: The Court found merit in the claimant's argument that ARTEX failed to controvert the right to compensation within the period fixed by Section 45 of the Workmen's Compensation Act. The failure to seasonably controvert constitutes a renunciation of the right to controvert the claim, and ARTEX must be deemed to have waived its right to question the compensability of Alexander's death. ARTEX did not file a petition under oath for reinstatement of its right to controvert, as required by law and the Commission's rules. On the admissibility of the police report: The Court ruled that the admission and consideration of the photostatic copy of the Malabon Police Department report by the Commission en banc were erroneous. While the Commission enjoys discretion in compensation proceedings, this does not include capriciously disregarding rules of fair play. The claimant was not afforded an opportunity to object to the report or present evidence in explanation or rebuttal. Furthermore, the report was submitted belatedly, more than three years after the initial decision, without explanation for the delay, casting doubt on its veracity and probative value. On whether the death arose out of and in the course of employment: The Court found that the evidence presented at the hearing before the Acting Referee established that Alexander suffered a compensable injury within his place of employment while engaged in an act related thereto (repairing to a store-boarding house for refreshments). Even conceding that his death resulted from the police shooting him while en route to the municipal hall, his death bore an intimate connection with the original injury, as without the stabbing, the subsequent events leading to his death would not have occurred. Therefore, his death was compensable.
Main Doctrine
Failure of an employer to seasonably controvert an employee's claim for compensation under the Workmen's Compensation Act constitutes a waiver of the right to question the compensability of the death or injury, and the employer cannot regain this right without filing a petition under oath for reinstatement as required by law. Furthermore, evidence submitted belatedly and without opportunity for the opposing party to object or rebut is inadmissible.