Solite v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Iluminado G. Solite, employed as a Radio Operator by the Bureau of Telecommunications, was diagnosed in 1969 with "rheumatoid arthritis with accompanying Neuritis, Anemia, secondary." He took sick leave from October 15, 1974, to December 15, 1974, and retired on December 31, 1974, at age 57, after nearly 22 years of service. Procedural History: Petitioner filed a claim for disability compensation on January 29, 1975, which the respondent Republic did not controvert. An Acting Referee awarded disability benefits, attorney's fees, and administrative fees. The Office of the Solicitor General (OSG) received this decision on October 17, 1975, and on November 19, 1975, filed a petition to elevate records for relief from judgment due to "volume and pressure of work." The Workmen's Compensation Commission (WCC) granted this petition and subsequently issued a decision disallowing the claim for lack of merit. The Petition: Petitioner seeks review of the WCC's decision, contending that the WCC erred in granting the Republic's petition for relief from judgment without sufficient grounds and in ruling on the merits of the case despite the finality of the Acting Referee's decision.
Issue(s)
Whether the respondent Commission erred in granting the respondent Republic's petition to elevate records despite the absence of any justifiable ground. Whether the respondent Commission erred in deciding the case on the merits notwithstanding the finality of the Acting Referee's decision dated September 29, 1975. Whether the respondent Republic's alleged "volume and pressure of work" constitutes excusable negligence warranting relief from judgment.
Ruling
The decision of the respondent Commission is reversed and set aside. The respondent Republic (Bureau of Telecommunications) is ordered to pay the petitioner the sum of P3,598.82 as disability benefits, P359.88 as attorney's fees, and P61.00 as administrative fees. The Republic is also required to reimburse the petitioner for his medical expenses supported by receipts.
Ratio Decidendi
On the error in granting the petition to elevate records and deciding on the merits: The Court sustained the petitioner's argument. While the OSG was not initially served notice as required by GA.O. Circular No. 69, the records showed notice of the petitioner's illness to the Republic. The Court clarified that the duty to submit a notice of controversion devolves upon the head of the employing office or agency, and it is only when the office decides to controvert the claim that the report must go through the OSG. If the employing office does not controvert, there is no need to involve the OSG. The Court noted that the OSG's practice of filing a general controversion without actual knowledge of the facts is void or invalid for being hearsay. Furthermore, a WCC circular requiring a copy of the notice and claim to be transmitted to the OSG, even if uncontroverted, was deemed to merely require transmission and not to render the Regional Office's decision invalid if violated; at most, it would expose the officer to administrative action. The Court emphasized that failure to send a copy to the OSG should not prejudice the claimant, as the Workmen's Compensation Act aims to protect the worker. On whether "volume and pressure of work" constitutes excusable negligence: The Court held that the Republic's alleged "volume and pressure of work" does not constitute excusable negligence. Relief from judgment is an exceptional remedy available only when there is no other adequate remedy at law and when the party has been unjustly deprived of a hearing or prevented from appealing due to fraud, accident, mistake, or excusable negligence. The Republic could have filed a motion for an extension of time to file a motion for reconsideration or a petition for review instead of letting the reglementary period lapse. The Court cannot sanction such a procedural lapse, even for the Government. The Republic must bear the consequences of its non-vigilance. On the finality of the Acting Referee's decision and waiver of defenses: By failing to controvert the claim within the prescribed period, the Republic waived all non-jurisdictional defenses. Consequently, the presumption of compensability remained in the petitioner's favor, as his illness arose in the course of his employment. The Court reiterated that when an employee is forced to retire due to ailments contracted during employment that disable him from continuing his job, he is entitled to compensation benefits for those illnesses, not merely because of old age or years of service.
Main Doctrine
The failure of the Republic to controvert a claim for compensation benefits within the prescribed period constitutes a waiver of all non-jurisdictional defenses, and the presumption of compensability remains in the claimant's favor, especially when the illness arose in the course of employment. Excusable negligence, such as 'volume and pressure of work,' is generally not a sufficient ground to grant a petition for relief from judgment, as the government should have exercised proper diligence or sought an extension of time.