Ruivivar v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Soledad R. Ruivivar, a classroom teacher employed by the Bureau of Public Schools, stopped working on September 2, 1971, due to toxic goiter and rheumatoid thyroid heart, rendering her disabled from labor. She filed a claim for disability compensation benefits. Procedural History: Regional Office No. 5 of the Workmen's Compensation Unit awarded disability benefits and medical expense reimbursement to Ruivivar. The Republic of the Philippines (Bureau of Public Schools), through the Office of the Solicitor General, filed a petition to elevate records for relief from judgment, alleging late receipt of the decision. The Acting Referee denied this petition but ordered the elevation of the records to the Workmen's Compensation Commission (WCC). The Petition: The Solicitor General contended that the Regional Office lacked jurisdiction over the respondent because the Office of the Solicitor General was not furnished a copy of the notice and claim for compensation. The WCC reversed the decision of the Regional Office, absolving the Republic of liability.
Issue(s)
Whether the Regional Office No. 5 acquired jurisdiction over the respondent Republic of the Philippines (Bureau of Public Schools) despite the Office of the Solicitor General not being furnished a copy of the notice and claim for compensation. Whether the illnesses of the claimant, toxic goiter and rheumatoid thyroid heart, are compensable under the Workmen's Compensation Act.
Ruling
The Supreme Court set aside the decision of the Workmen's Compensation Commission and ordered the Republic of the Philippines (Bureau of Public Schools) to pay the claimant P6,000.00 as disability benefit, P3,063.23 as reimbursement for medical expenses, P600.00 as attorney's fees, and P61.00 as administrative fee.
Ratio Decidendi
On the issue of jurisdiction: The Court held that the contention of the Solicitor General that Regional Office No. 5 acquired no jurisdiction because the Office of the Solicitor General was not furnished a copy of the notice and claim for compensation has no merit. Citing the case of Dinero vs. Workmen's Compensation Commission, et al., the Court stated that failure of the government agency concerned to comply with the provision requiring claims against the Republic to be transmitted to the Solicitor General cannot be the instrument of injustice against the claimant-employee nor override the statutory sanction for non-controversion. The Workmen's Compensation Act is a social legislation designed to give relief to the working man and should be liberally construed to attain its purpose, with all doubts resolved in favor of the petitioner to serve the ends of social justice. On the compensability of illnesses: The Court found that the respondent, Bureau of Public Schools, did not present any evidence to contradict the evidence adduced by the petitioner that her illnesses supervened during her employment. Therefore, there is a presumption of compensability and causal relation of her illness to her job. Furthermore, the petitioner adduced sufficient evidence to establish that her illness was either caused or aggravated by her work as a public school teacher in the Bureau of Public Schools. The Regional Office No. 5 had found the claim meritorious, and the Employer's Report admitted non-controversion on the ground that the claimant's illnesses were acquired in her regular occupation, admitting the fact of sickness and disability.
Main Doctrine
Failure of a government agency to comply with procedural rules regarding service of notice and claim for compensation does not divest the Workmen's Compensation Commission of jurisdiction over the respondent State, especially when the claim is not controverted, as the Workmen's Compensation Act is a social legislation to be liberally construed in favor of the employee.