Galang v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: The late Lorenzo Galang, employed as a factory worker by Procter and Gamble, Inc. for over 23 years, died on December 9, 1970, from bronchogenic carcinoma of the left lung. His widow, Anicia Vda. de Galang, filed a claim for death compensation benefits under the Workmen's Compensation Act, asserting that the illness was contracted in the course of his employment and resulted in his death. Procedural History: The claim was initially awarded by Regional Office No. 4 of the Workmen's Compensation Unit. However, Procter and Gamble, Inc. filed a petition for review, leading to the Workmen's Compensation Commission reversing the award on December 31, 1975. The Commission found that the cause of death was cancer, not pulmonary tuberculosis as initially alleged, and questioned the work-relatedness of the illness and the timeliness of the claim and controversion. The Petition: This petition for review on certiorari seeks to overturn the Workmen's Compensation Commission's decision. The petitioner argues that the employer failed to seasonably controvert the claim, thereby waiving defenses. Furthermore, the petitioner contends that under the Workmen's Compensation Act, there is a presumption of compensability for illnesses contracted during employment, and the employer failed to provide substantial evidence to overcome this presumption. The petitioner also asserts that the claim was not barred by prescription, citing established jurisprudence that such claims prescribe in ten years under the Civil Code.
Issue(s)
Whether the claim for death compensation benefits is barred by prescription. Whether the employer, Procter and Gamble, Inc., seasonably controverted the claim. Whether the death of Lorenzo Galang due to bronchogenic carcinoma of the left lung is compensable under the Workmen's Compensation Act.
Ruling
The Supreme Court reversed and set aside the decision of the Workmen's Compensation Commission. It directed Procter and Gamble, Inc. to pay the claimant death compensation benefits, attorney's fees, reimbursement for medical, hospital, and burial services, administrative fees to the WCC, and costs.
Ratio Decidendi
On the issue of prescription: The Court held that the claim for death compensation benefits is not barred by prescription. While Section 24 of Act 3428, as amended, provides for a three-month period after death for filing a claim, the Court reiterated its ruling that such claims prescribe in ten years under Article 1144(2) of the Civil Code, citing several previous decisions. Since the claim was filed within five years from the decedent's death, the Regional Office had jurisdiction to entertain the claim. The failure to file within the period provided in Section 24 does not affect the jurisdiction of the Commission. On the issue of timely controversion: The Court found that the employer failed to seasonably controvert the claim. The employer admitted knowledge of the decedent's illness on May 8, 1970, through its foreman. However, the notice of controversion was only given on June 30, 1970, which is beyond the fourteen-day period from disability or ten-day period after knowledge of the alleged accident or illness as required by Section 45 of the Workmen's Compensation Act. This failure to controvert seasonably results in the waiver of all non-jurisdictional defenses. On the compensability of the illness: The Court held that the death of Lorenzo Galang due to bronchogenic carcinoma of the left lung is compensable. It reiterated the settled doctrine that under the Workmen's Compensation Act, a claim is presumed compensable in the absence of substantial evidence to the contrary. The Act is a social legislation designed to give relief to the working man. Even if the cause of death is unknown, the right to compensation subsists. The Court noted that the deceased was employed for over 23 years in a factory manufacturing soap, edible oil, and detergents, exposing him to chemicals and machine emissions. The employer failed to present substantial proof that the cancer was not work-connected or aggravated by the nature of his employment. The Court further emphasized that expert medical testimony is not always required to demonstrate that cancer can be induced by chemicals involved in such manufacturing processes, citing previous rulings.
Main Doctrine
The Workmen's Compensation Act is a social legislation presumed to be compensable, and the employer bears the burden of overcoming this presumption with substantial evidence. Failure to seasonably controvert a claim results in the waiver of non-jurisdictional defenses. Claims under the Act prescribe in ten years.