Pascua v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Justino Pascua, an employee of Sanz Steel R.B.M., filed a claim for disability compensation alleging that he contracted pulmonary tuberculosis and fistula en anu in the course of his employment. He asserted that these conditions incapacitated him from work starting October 18, 1973. Procedural History: The claimant filed his claim on November 8, 1974. As the employer, Sanz Steel R.B.M., did not controvert the claim, an award was initially granted by the Acting Chief of Section on January 28, 1975. The employer filed a Motion for Reconsideration, which was set for hearing. However, the employer failed to appear at the rescheduled hearing, leading to the denial of their motion and the elevation of the case to the Commission. On December 13, 1975, the Workmen's Compensation Commission reversed the Referee's award, finding insufficient evidence to establish the claimant's disability and noting that the claim focused on fistula en anu, not pulmonary tuberculosis. The Petition: The petitioner seeks review of the Commission's decision, arguing that the Commission erred by ignoring Section 45 of the Workmen's Compensation Act. This section mandates that failure to controvert a claim within the prescribed period constitutes a waiver of the right to do so, unless reasonable grounds for the delay are provided. The petitioner highlights that the employer received notice of the claim on November 27, 1974, but failed to file an employer's report or controvert the claim. Furthermore, the petitioner contends that the Commission overlooked that the employer did not present evidence to support its motion for reconsideration, having waived its right to do so by failing to appear at the hearing. The petitioner also asserts the legal presumption that an illness supervening during employment is presumed to have arisen from or been aggravated by it, a presumption not overcome by substantial evidence.
Issue(s)
Whether the respondent Commission erred in reversing the award despite the employer's failure to controvert the claim within the period prescribed by Section 45 of the Workmen's Compensation Act. Whether the medical reports submitted by the claimant sufficiently established his disability arising from his employment.
Ruling
The decision of the respondent Commission is set aside. Sanz Steel R.B.M. is ordered to pay Justino Pascua the maximum amount of Six Thousand (P6,000.00) Pesos as disability compensation, Atty. Juan Moreno the sum of Three Hundred (P300.00) Pesos as attorney's fees, and Sixty-one (P61.00) Pesos to the Workmen's Compensation Fund.
Ratio Decidendi
On the failure to controvert the claim: The Court reiterated the principle that under Section 45 of the Workmen's Compensation Act, an employer must controvert the right to compensation within a specified period (14 days from disability or 10 days after notice). Failure to do so constitutes a waiver of the right to controvert, unless reasonable grounds for the delay are presented and accepted by the Commissioner. In this case, the employer received notice on November 27, 1974, and did not file an employer's report or answer. The employer did not seek to reinstate its right to controvert nor offer any explanation for its failure in its pleadings. The respondent Commission's reversal of the award, based on a perceived lack of substantial evidence, ignored this mandatory procedural requirement. The Court cited Tan Lim Te v. Workmen's Compensation Commissioner and Reynaldo vs. Republic of the Philippines to emphasize that failure to controvert prevents the employer from proving anything against the claim, including that the illness is not work-connected. On the sufficiency of evidence and presumption of work-connection: The Court found that the Hearing Officer correctly issued an award based on the claimant's documentary evidence, which included the notice of claim and medical reports. These reports indicated that Justino Pascua suffered from both fistula en anu and pulmonary tuberculosis. The respondent Commission's assertion that the claim was only for fistula en anu and not PTB was contradicted by the notice of claim itself, which specified "fistula & t.b." Furthermore, the Commission's reasoning that the claimant was not disabled because he worked and collected wages in certain periods was flawed, as the employer failed to formally offer these documents as evidence during the hearing on its motion for reconsideration, thereby waiving its right to present them. The Court also restated the legal presumption that when an illness supervenes during employment, it is presumed to have arisen out of or was aggravated by the employment, and this presumption can only be overcome by substantial evidence to the contrary, which the employer failed to provide.
Main Doctrine
The failure of an employer to controvert a claim for compensation within the period prescribed by law constitutes a waiver of the right to question the claim, and the award may be based on the claimant's evidence alone, absent any justified explanation for the delay.