Superior Concrete Products, Inc. v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Carmelito A. Benoza, a laborer for Superior Concrete Products, Inc., filed a notice of sickness and claim for compensation on April 20, 1971, alleging he contracted pulmonary tuberculosis (PTB) in the course of his employment on February 2, 1963, and stopped working on March 24, 1967. The employer received notice on April 26, 1971, but controverted the claim only on July 12, 1971. An award was initially granted but later vacated upon the employer's motion for reconsideration, and the case was re-docketed as RO 4-W.C.C. No. 14617. This case was dismissed without prejudice due to the claimant's failure to appear but was later revived. On September 1, 1973, Benoza filed a new claim, docketed as Case No. 144437, which resulted in an award of P6,000.00 for disability from March 26, 1967, to October 25, 1973. Procedural History: The employer filed a motion for reconsideration of the award in Case No. 144437, alleging denial of due process due to the pendency of a prior case and lack of opportunity to present evidence. This motion was denied, and the award was affirmed by the Workmen's Compensation Commission en banc on November 11, 1975. The employer then filed the present petition for review. The Petition: Superior Concrete Products, Inc. seeks to set aside the award, arguing that the Commission gravely erred in rendering a decision while another case involving the same claim was pending, constituting a denial of due process, and that the claim was barred by prescription and laches.
Issue(s)
Whether the respondent Commission gravely erred in rendering a decision in Case No. 144437 while another case involving the same claim was still pending, thereby resulting in a denial of due process. Whether the claim for compensation is barred by prescription and laches.
Ruling
The petition is denied, and the decision of the Workmen's Compensation Commission is affirmed with modification. The employer is ordered to pay the claimant P6,000.00 as disability compensation, provide necessary services and supplies for recovery, pay attorney's fees of P600.00 to claimant's counsel, pay P61.00 as administrative fees to the Commission, and pay costs.
Ratio Decidendi
On the issue of denial of due process: The Court held that there was no denial of due process. Although a prior case (No. 122718, later redocketed as 14617) was dismissed without prejudice and subsequently revived, the filing of a new claim (No. 144437) did not prejudice the employer, especially since notice of this second claim was sent and received on September 3, 1973. The employer failed to file a controversion report within the reglementary period after receiving notice of the second claim. The Court emphasized that procedural due process requires an opportunity to be heard, not necessarily a prior notice, and that the employer had ample opportunity to present its case, including filing a motion for reconsideration and elevating the matter to the Commission en banc. The employer's failure to act within the prescribed period justified the issuance of an outright award based on documentary evidence. On the issue of prescription and laches: The Court ruled that the claim was not barred by prescription or laches. While the claimant contracted pulmonary tuberculosis in February 1963, his cause of action for compensation accrued only in March 1967 when he became disabled from work and could no longer pursue his occupation. The filing of the claim in April 1971 was well within the ten-year prescriptive period for compensation cases. The Court also noted that any delay in filing could be attributed to the claimant's status as an unschooled laborer ignorant of his rights. Furthermore, the employer's failure to controvert the claim within fourteen days after disability or ten days after knowledge thereof resulted in the loss of its right to raise non-jurisdictional defenses, thereby admitting the claim's compensability.
Main Doctrine
The failure of an employer to controvert a claim for compensation within the reglementary period results in the loss of the right to raise non-jurisdictional defenses and constitutes an admission of the claim's compensability. Furthermore, the accrual of a cause of action for compensation benefits is based on the employee's disability to pursue their occupation due to illness, not merely the contraction of the illness itself.