Sebastian v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Romeo Sebastian was employed by private respondent Philippine Iron Manufacturing Co., Inc. as a grinder since 1964. On December 21, 1974, he contracted tuberculosis (P.T.B.), which rendered him unable to work. He filed a claim for disability compensation against his employer. Procedural History: Petitioner filed a notice and claim for disability compensation on March 24, 1975. Due to the private respondent's failure to controvert the claim within the prescribed period, the Acting Referee of Regional Office No. 4, Manila, rendered a decision on October 8, 1975, awarding compensation to the petitioner. The private respondent appealed this decision, arguing it was denied its day in court. The Workmen's Compensation Commission, in a decision dated December 27, 1975, reversed the Acting Referee's award and absolved the private respondent of liability. The Petition: Petitioner Romeo Sebastian filed this petition for review of the Workmen's Compensation Commission's decision. He contends that the Commission erred in reversing the Acting Referee's award, arguing that the private respondent failed to controvert the claim and was presumed to have received the notice sent by the Workmen's Compensation Unit. The petitioner also presented evidence of his continued employment and the nature of his disability.
Issue(s)
Whether the private respondent waived its defenses by failing to controvert the petitioner's claim for disability compensation within the period prescribed by law. Whether the private respondent was denied due process.
Ruling
The Supreme Court reversed and set aside the decision of the respondent Workmen's Compensation Commission. It ordered respondent Philippine Iron Manufacturing Co., Inc. to pay claimant-petitioner Romeo Sebastian disability compensation, attorney's fees, reimbursement for medical and hospital expenses, and to provide future medical services, as well as to pay administrative fees.
Ratio Decidendi
On Issue 1: The Court held that the private respondent waived all its defenses by failing to controvert the claim within the period prescribed by law. The records showed that the Workmen's Compensation Unit sent the required notice and Form No. 3 to the private respondent on July 15, 1975, but the respondent failed to accomplish the form or tender an answer. Settled jurisprudence dictates that when a letter duly directed and mailed to a known addressee has not been returned, it is presumed that the addressee received the letter. Therefore, the burden was on the private respondent to prove by indubitable evidence that it did not receive the notice, which it failed to do. The failure to controvert generates a waiver of all non-jurisdictional defenses. Furthermore, the Court noted that the private respondent's foreman's knowledge of the petitioner's ailment is knowledge of the employer, and the company had only 10 or 14 days from such knowledge to controvert the claim, which it failed to do. On Issue 2: The Court found that the private respondent was not denied due process. The records clearly indicated that the Workmen's Compensation Unit sent the required notice and Form No. 3 to the private respondent on July 15, 1975. The presumption of receipt of mailed letters to a known addressee applies, and the private respondent failed to present any evidence to overcome this presumption. The claim that the petitioner abandoned his work was also disputed by the respondent's own certification showing continued SSS contributions until February 1975, confirming his employment status. Thus, the private respondent had ample opportunity to controvert the claim and present its defenses.
Main Doctrine
The failure of an employer to controvert a claim for compensation within the period prescribed by law constitutes a waiver of all available defenses, including those that go into the merit of the case. This is because the law presumes that the employer has admitted the compensability of the claim. Additionally, notices sent by mail to a known addressee are presumed to have been received, and the burden rests upon the employer to prove non-receipt by indubitable evidence.