Republic v. Workmen's Compensation Comm'n
REITERATIONFacts
The Antecedents: Angel Costales, formerly an assistant supply officer in the Office of the Solicitor General, contracted an illness diagnosed as hypertension malignant and genitourinary disturbances in 1965. This illness progressed, leading to a stroke on August 4, 1971, diagnosed as severe hypertension and cerebral vascular accident, causing paralysis of his right side. Consequently, Costales was forced to stop working and was retired due to disability on October 1, 1971, at the age of 64. He incurred significant medical expenses for his treatment and hospitalization. Procedural History: Angel Costales filed a claim for compensation with the Regional Office No. IV, Department of Labor, in 1972. The Office of the Solicitor General filed a notice of controversion. The Acting Referee ordered the Office of the Solicitor General to pay compensation benefits, which was affirmed with modifications by the Chairman of the Workmen's Compensation Commission, awarding disability benefits, reimbursement of medical expenses, and attorney's fees. The Office of the Solicitor General's motion for reconsideration was dismissed by the Commission, which deemed the decision final and executory due to late filing. This led to the present petition for review. The Petition: The Republic of the Philippines, through the Office of the Solicitor General, filed this petition for review, assigning three main errors. Primarily, it contends that the Workmen's Compensation Commission erred in declaring its decision final and executory despite the timely filing of motions for extension to file a motion for reconsideration. It also argues that the Commission erred in finding that Angel Costales retired due to a compensable illness and in finding that the petitioner forfeited its right to controvert the claim. The petitioner argues that its motions for extension were filed within the reglementary period and that the illness was not sufficiently proven to be work-related, nor was the right to controvert forfeited.
Issue(s)
Whether the Workmen's Compensation Commission erred in declaring the decision of its Chairman final and executory despite the filing of a motion for extension of time to file a motion for reconsideration within the reglementary period. Whether the Chairman of the WCC erred in finding that respondent Angel Costales retired from the service due to his illness, which was considered compensable. Whether the Chairman of the WCC erred in finding that the petitioner (OSG) forfeited its right to controvert the claim filed by respondent Angel Costales.
Ruling
The Supreme Court affirmed the decision of the Workmen's Compensation Commission. The petitioner was ordered to pay the heirs of Angel Costales disability benefits, reimbursement for medical expenses, attorney's fees to claimant's counsel, and administrative fees to the WCC.
Ratio Decidendi
On the issue of the decision being declared final and executory: The Court found that the OSG's motions for extension of time to file a motion for reconsideration were filed within the reglementary period, considering the date of mailing as the date of filing. Therefore, the motion for reconsideration filed on May 7, 1974, was deemed timely. However, despite this procedural finding, the Court proceeded to rule on the merits of the case. On the issue of compensability of the illness and retirement: The Court held that the evidence established that Angel Costales contracted an illness (hypertension, genitourinary disturbances, and later a stroke leading to paralysis) while in the service. The Court reiterated the legal presumption that an illness or injury contracted during employment is compensable, relieving the claimant of the burden of proving causation. The employer bears the burden to disprove this presumption with substantial evidence. On the issue of forfeiture of the right to controvert: The Court found that the OSG was aware of the claimant's ailment as early as 1965 and at the time of his retirement in 1971. Despite this knowledge, the OSG failed to file a notice of controversion within the period prescribed by Section 45 of the Workmen's Compensation Act. Consequently, the OSG was deemed to have renounced its right to challenge the claim on non-jurisdictional grounds, including the non-compensability of the illness. Even if the right to controvert were not forfeited, the OSG failed to rebut the claim with competent evidence.
Main Doctrine
The presumption of compensability under the Workmen's Compensation Act dispenses with the need for the claimant to prove causation, and the burden to overthrow this presumption rests upon the employer. Failure to seasonably controvert a claim results in the forfeiture of non-jurisdictional defenses.