Mulingtapang v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Leonor S. Mulingtapang, mother of the deceased Hernando S. Mulingtapang, filed a claim for death benefits against Marcelo Steel Corporation, Hernando's employer. Hernando, employed as a maintenance lubricator, died on October 26, 1974, from pneumonia, secondary acute leukemia, which he began to feel on September 3, 1974. Procedural History: A claim for death benefits was filed on November 29, 1974. An acting referee of the Department of Labor's Workmen's Compensation Unit rendered a decision on October 23, 1975, ordering the employer to pay death benefits and burial expenses, relying on the presumption of compensability as the illness supervened in the course of employment and a physician's certification that the illness was aggravated by work. However, upon motion for reconsideration by the employer, the Workmen's Compensation Commission reversed the decision, holding that the employer had presented substantial evidence to overcome the presumption, stating that leukemia or pneumonia is not an occupational disease and the deceased's work as a lubricator did not require strenuous activity. The Petition: Petitioner Leonor S. Mulingtapang filed a petition for certiorari with the Supreme Court, arguing that the respondent Commission gravely abused its discretion in finding that the evidence presented by the respondent corporation was substantial enough to overcome the presumption of compensability.
Issue(s)
Whether the respondent Commission gravely abused its discretion in finding that the evidence presented by the respondent corporation was substantial enough to overcome the presumption of compensability. Whether the claim for death benefits was effectively controverted.
Ruling
The Supreme Court reversed and set aside the decision of the respondent Commission. Respondent Marcelo Steel Corporation was directed to pay the claimant death benefits in the amount of P6,000.00, burial expenses in the sum of P200.00, and attorney's fees equivalent to five percent (5%) of the benefits awarded. Additionally, the employer was ordered to pay the Workmen's Compensation Commission P61.00 and costs.
Ratio Decidendi
On the issue of whether the respondent Commission gravely abused its discretion in finding that the evidence presented by the respondent corporation was substantial enough to overcome the presumption of compensability: The Supreme Court found the petition meritorious and reversed the Commission's decision. The Court held that the Commission's conclusion that the deceased's work as a lubricator maintenance worker did not require strenuous work was unsupported by any evidence in the records. The only evidence presented by the respondent corporation consisted of affidavits from three doctors opining that leukemia is not an occupational disease, nor work-connected or aggravated, and could be contracted by anyone. The Court reiterated that such mere opinions do not meet the required quantum of evidence to destroy the legal presumption of compensability. The evidence must be substantial enough that a reasonable mind accepts it as adequate to support a conclusion, and the employer's burden is to disconnect the illness from employment by substantial evidence, not merely create doubt. The Court emphasized that the legal presumption of compensability is applied with rigor even in the absence of a definite medical cause, as long as the illness supervened in the course of employment, because the purpose of the Workmen's Compensation Act is to provide relief to workmen and must be liberally construed. On the issue of whether the claim for death benefits was effectively controverted: The Supreme Court found that the claim for death benefits filed on November 29, 1974, was not effectively controverted. The Employer's Report filed on December 9, 1974, was too late, as it should have been filed within ten days from knowledge of the disability or within 14 days from the disability or death, pursuant to Section 45 of the Workmen's Compensation Act. The controversion filed on September 10, 1974, pertained to the illness contracted on September 3, 1974, not the death on October 26, 1974. As the claim for death benefits was not timely controverted, the respondent corporation renounced its right to challenge the validity of the claim and was barred from interposing non-jurisdictional defenses, such as non-compensability. The respondent Commission erred in ignoring the effects of this non-controversion.
Main Doctrine
The Supreme Court reiterated that the presumption of compensability under the Workmen's Compensation Act is a rebuttable presumption that arises when an illness supervenes in the course of employment. The employer has the burden to present substantial evidence to overcome this presumption, and mere medical opinions that an illness is not occupational, work-connected, or aggravated are insufficient to discharge this burden. Furthermore, failure to timely controvert a claim for death benefits results in the renunciation of the employer's right to challenge the claim's validity.