Saril v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Mila Luz T. Saril, a teacher employed at To-oy Elementary School, died on March 27, 1971, due to "internal hemorrhage secondary to acute enterocolitis" while six (6) months pregnant. Her husband, Rodito T. Saril, filed a claim for compensation benefits. Procedural History: The claim was filed on May 14, 1971. The employer, Bureau of Public Schools, entered a "tentative controversion" on July 7, 1971, stating that the cause of death was not clearly shown to be employment-related. Despite multiple notices and extensions, the employer failed to submit its memorandum and supporting affidavits. The Hearing Officer issued an award in favor of the claimant on July 28, 1975. A motion to set aside the award filed by the employer was denied on November 20, 1975. The Workmen's Compensation Commission en banc set aside the award on December 30, 1975, reasoning that the physician's report indicated no causal relation between the ailment and the work, and that the claimant needed to show a "legal linkage" despite the presumption. The Petition: The claimant, Rodito T. Saril, assails the decision of the Commission setting aside the award.
Issue(s)
Whether the employer timely controverted the claim for compensation. Whether the presumption of compensability under the Workmen's Compensation Act is available to the heirs of the deceased employee. Whether the physician's report stating no causal relation is sufficient to overcome the presumption of compensability.
Ruling
The Supreme Court found the decision of the Commission contrary to law and jurisprudence, setting aside the same and reinstating the award of the referee with a modification regarding attorney's fees.
Ratio Decidendi
On the issue of timely controversion: The Court held that the claim for compensation was not controverted on time. The employer was notified of the death, but no employer's report contesting the claim was filed. The "tentative controversion" was not followed by a formal controversion, and the employer failed to present any evidence despite numerous opportunities over a period of nearly four years. Section 45 of the Workmen's Compensation Act mandates that failure to file a notice of controversion within the statutory period constitutes a renunciation of the right to contest the claim, unless reasonable grounds for the failure are shown. The Court emphasized that by operation of law, failure to timely controvert means the employer waived the right to interpose any defenses. Therefore, the Referee was justified in issuing an outright award based on the claimant's evidence. On the issue of the legal presumption of compensability: The Court affirmed that the legal presumption of compensability established by Section 44 of the Workmen's Compensation Act is available to the heirs of the deceased, Mila Saril. The Commission's argument that the ailment was not work-connected ignored this legal presumption. The Court reiterated its consistent holding that where an illness occurs in the course of employment, it is presumed to have arisen out of or been aggravated by the employment. The employer has the burden of proving the contrary by substantial evidence. The Court cited several cases, including Aguedo del Rosario, Abana, Maria Cristina Fertilizer Corp., and Belmonte, to support the principle that it is not necessary for employment to be the sole factor, and that a probable hypothesis is sufficient. The employer must discharge the burden of proof, and mere opinions of physicians or conjectures are insufficient to overcome the presumption. On the issue of the physician's report: The Court found the argument that the physician's report contained a "No" answer to the question of direct causal relation to be without merit. Such a negative answer, even if part of the claimant's evidence, is insufficient in itself to destroy the legal presumption of compensability. Similar to mere opinions of employer-provided doctors or the Commission's medical rating officer, it cannot prevail over the statutory presumption. The Court cited Jabasa, Cama, and Consolacion Amador to underscore that the presumption mandated by law is paramount.
Main Doctrine
Failure to timely controvert a claim for compensation under the Workmen's Compensation Act constitutes a renunciation of the employer's right to contest the claim and interpose any defenses. Furthermore, where an illness occurs in the course of employment, there is a legal presumption of compensability, and the employer bears the burden of proving the contrary by substantial evidence.