Carrera v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Francisco Carrera, an elementary school teacher, stopped teaching on October 4, 1974, due to ill health, as advised by his physician. On March 14, 1975, he filed a notice of injury or sickness and claim for compensation, supported by a physician's report dated March 14, 1975, diagnosing him with moderately advanced pulmonary tuberculosis since July 10, 1972. Procedural History: Due to the respondent employer's failure to controvert the claim on time, the Workmen's Compensation Unit issued a letter-award granting disability compensation of Six Thousand Pesos. The respondent employer filed a motion for reconsideration, which was denied, and the case was elevated to the Workmen's Compensation Commission (WCC). The WCC reversed the referee's award, stating that failure to controvert does not automatically make a claim compensable and that substantial evidence of compensability is required. The WCC also noted the lack of chest x-ray findings to support the diagnosis. The Petition: Francisco Carrera appealed to the Supreme Court, arguing that the WCC erred in holding that pulmonary tuberculosis is not compensable despite non-controversion and in ruling that he failed to establish by convincing evidence that the illness was contracted in the course of employment or aggravated thereby.
Issue(s)
Whether the failure to controvert the claim within the statutory period results in the presumption of compensability. Whether a physician's report, without accompanying x-ray findings, is sufficient to establish the compensability of pulmonary tuberculosis.
Ruling
The Supreme Court set aside the decision of the Workmen's Compensation Commission and affirmed the referee's award granting disability compensation of Six Thousand Pesos (P6,000.00) to the claimant. The employer was also directed to furnish claimant with services and supplies for his recovery, pay attorney's fees, and pay administrative fees.
Ratio Decidendi
On the issue of failure to controvert: The Court reiterated the oft-repeated rule that a claim for compensation is presumed compensable under the Workmen's Compensation Act, especially when the illness occurs in the course of employment. Section 44 of the Act establishes this presumption. The Court emphasized that the petitioner's position is strengthened by the late controversion of his claim. The employer, despite being aware of Carrera's cessation of teaching, failed to file an employer's report controverting the claim within the ten-day period after receipt of notice. The Court has consistently ruled that failure to controvert results in the loss of non-jurisdictional defenses and an ultimate admission of compensability, citing numerous previous decisions. Therefore, inasmuch as the claim was not properly and/or timely controverted, and no evidence was submitted by the employer to rebut the fact of illness, the referee's award was justified. On the sufficiency of the physician's report: The Court disagreed with the WCC's assertion that chest x-ray findings are indispensable prerequisites for compensation. Under Section 49 of the Workmen's Compensation Act, a report of an attending physician may be received as evidence. The Court categorically held that an x-ray or other laboratory report is not an indispensable prerequisite to compensation, and their absence does not invalidate the diagnosis appearing in the physician's report. The Court cited its ruling in Landayan vs. Workmen's Compensation Commission, et al., where it was held that the absence of x-ray examination and/or laboratory findings will not invalidate a diagnosis appearing on a physician's report. The Court reiterated that decisions like the one rendered by the respondent Commission convert the applicable provisions of the Act and settled jurisprudence into empty rhetoric.
Main Doctrine
Failure to controvert a claim for compensation within the period provided by law results in the loss of non-jurisdictional defenses and an ultimate admission of compensability, provided there is substantial evidence that the injury or sickness is compensable. A physician's report is admissible as evidence, and an x-ray or laboratory findings are not indispensable prerequisites for compensation.