Natividad v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Victoria Natividad filed a claim for compensation against the Bureau of Public Schools for illnesses allegedly contracted during her employment as a teacher, namely hypertension, nervousness, rheumatism, and pneumonia. She alleged that she stopped working on October 23, 1973, due to these ailments. Medical certificates from Dr. Jose L. Occena and Dr. Juan Yason attested to her essential hypertension and hypertrophic osteoarthritis, which required her to rest from work. Procedural History: A notice of sickness and claim for compensation was filed on March 31, 1975. A notice was sent to the employer, and a tentative controversion was filed. On September 25, 1975, Acting Referee Gregorio Calasan dismissed the claim for lack of merit without a hearing. Petitioner's motion for reconsideration and/or to re-open the case was denied by Acting Referee Roberto Blanco, who elevated the records to the Workmen's Compensation Commission (WCC). The WCC affirmed the dismissal, stating that the illnesses were not directly caused by or aggravated by the employment, were not disabling as they could be controlled by diet and medication, and that the claimant optionally retired without evidence of disability. The Petition: Petitioner sought a review of the WCC decision, arguing that she was denied due process by the dismissal of her claim without a hearing and an opportunity to present evidence.
Issue(s)
Whether the dismissal of the claim without a hearing violated petitioner's right to due process. Whether the failure to file a formal notice of employer's report of sickness constituted non-controversion and waiver of defenses. Whether there was substantial evidence to support the validity of the claim. Whether the petitioner's ailments were legally presumed to be compensable. Whether the petitioner's optional retirement constituted proof of disability.
Ruling
The Supreme Court set aside the decision of the respondent Commission and ordered the Republic of the Philippines (Bureau of Public Schools) to pay petitioner Victoria Natividad P6,000.00 as maximum compensation for temporary partial disability, to provide necessary services, appliances, and supplies for her recovery, to pay attorney's fees of P600.00, and to pay P61.00 to the Workmen's Compensation Fund.
Ratio Decidendi
On the issue of denial of due process: The Court held that the dismissal of the claim without a hearing, despite the Solicitor General's admission that no hearing was held, constituted a denial of due process. Expediency in disposing of cases cannot justify the sacrifice of procedural due process, which is a constitutional safeguard and demands elementary requirements of fairness. The Court emphasized that due process is not a mere formality but a fundamental right. On the issue of non-controversion and waiver of defenses: The Court found that although a "tentative controversion" was registered, it was not followed by a formal answer or opposition. Furthermore, the employer failed to file the required notice of employer's report concerning the sickness of Victoria Natividad. The Court reiterated its established jurisprudence that failure to file such a report constitutes non-controversion of the claim and a waiver of non-jurisdictional defenses, citing Sebastian vs. WCC and other cases. On the issue of substantial evidence: The Court ruled that substantial evidence is sufficient to justify an award in proceedings before the Workmen's Compensation Commission, and the rule of preponderance of evidence is not strictly followed. The medical certificates from Dr. Occena and Dr. Yason, despite being reports, were considered admissible as substantial evidence under Section 49 of the Workmen's Compensation Act, even without the physicians' testimony, as per Pioneer Ceramics, Inc. vs. Samia. On the issue of presumption of compensability: The Court found that the respondent Commission ignored the legal presumption of compensability established by Section 44(1) of the Workmen's Compensation Act. This presumption, applied with utmost liberality due to the law's social and humane character, means that the exact medical cause of the ailment is not significant, and the employment's contribution, even if small, in aggravating the ailment is material and decisive, as held in Abana vs. Quisumbing and Bautista vs. WCC. On the issue of optional retirement and disability: The Court clarified that disability occurs when there is a loss or diminution of earning power due to sickness arising out of or aggravated by employment. The petitioner's optional retirement at age 63, occurring after she stopped reporting for duty due to her ailments, was considered an indication of her physical incapacity to render efficient service. Citing Romero vs. Workmen's Compensation Commission, the Court stated that optional retirement, in such circumstances, strengthens rather than defeats a claim for disability compensation, as it confirms the resulting disability.
Main Doctrine
The dismissal of a claim for compensation without a hearing, thereby denying the claimant an opportunity to present evidence, constitutes a violation of due process. Furthermore, failure to file a notice of employer's report of sickness constitutes non-controversion and waiver of defenses. The presumption of compensability under the Workmen's Compensation Act, coupled with substantial evidence, mandates an award for disability.