Natividad v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Pelagia Natividad, as the surviving spouse, pursued a claim for disability benefits on behalf of her deceased husband, Cirilo Andres. Andres was employed by Canlubang Sugar Estate as a coconut caretaker for many years, earning an average weekly wage of P60.00. He was diagnosed with chronic peptic ulcer in 1962, which necessitated an operation at the Philippine General Hospital, with expenses covered by the employer. His illness recurred, and by November 1969, at the age of 52, he was forced into disability retirement due to the chronic peptic ulcer. He later died on December 22, 1973, at the age of 56, from bronchial asthma. Procedural History: Prior to his death, Cirilo Andres filed a claim for disability benefits on October 29, 1973, with the Workmen's Compensation Unit, Department of Labor, citing chronic peptic ulcer as the disabling illness that led to his retirement in November 1969. During the pendency of this claim, Andres passed away and was substituted by his surviving spouse, Pelagia Natividad. The acting referee of the Workmen's Compensation Commission ruled in favor of the petitioner, awarding P6,000.00 in disability benefits. However, the respondent employer moved for reconsideration, and the Workmen's Compensation Commission, on November 19, 1975, reversed the referee's decision, deeming the claim non-compensable due to the time elapsed between the onset of disability and death, and also considering the claim as prescribed. The Petition: This petition for review on certiorari seeks to overturn the decision of the Workmen's Compensation Commission. The petitioner argues that the Commission erred in treating the claim as one for death benefits when it was filed as a disability compensation claim under Section 14 of the Workmen's Compensation Act. Furthermore, the petitioner contends that the Commission incorrectly ruled the claim as prescribed, asserting that the reckoning point for prescription should be the date of effective disability (November 1969) rather than the onset of the illness (1962). The petitioner also highlights the employer's failure to timely controvert the claim, thereby waiving all defenses and constructively admitting compensability. The petition asserts that the chronic peptic ulcer, which caused the disability and retirement in 1969, was either directly caused by or aggravated by the nature of the deceased's employment.
Issue(s)
Whether the Workmen's Compensation Commission gravely abused its discretion in treating a claim for disability compensation as a claim for death benefits. Whether the claim for disability benefits had prescribed. Whether the chronic peptic ulcer of the deceased employee was due to or aggravated by the nature of his work. Whether the respondent employer effectively controverted the employee's claim.
Ruling
The Supreme Court reversed and set aside the decision of the respondent Workmen's Compensation Commission. The respondent employer was ordered to pay the petitioner P6,000.00 as disability compensation, reimburse medical and hospital expenses, pay attorney's fees of 5%, and pay administrative fees.
Ratio Decidendi
On the issue of treating the claim as for death benefits: The Supreme Court held that the claim was filed under Section 14 of the Workmen's Compensation Act for disability compensation, not under Section 8 for death benefits. The death of the claimant during the pendency of the disability claim did not absolve the employer from liability for disability compensation, nor did it authorize the WCC to convert the claim to one for death benefits. The Court found that the WCC committed grave abuse of discretion by treating the disability claim as one for death benefits and dismissing it on the ground that death occurred more than two years after the disabling illness. The award by the acting referee was clearly for disability benefits. On the issue of prescription: The Supreme Court ruled that the respondent Commission's finding that the claim had prescribed was without factual and legal basis. The reckoning point for prescription is not the onset of the illness but the date of effective disability by reason of the illness, as disability compensation accrues only from the time the workman's earning power is lost or impaired. It was clear that while Cirilo Andres acquired his peptic ulcer in 1962, it caused his effective disability from labor only in 1969. Therefore, the claim filed in 1973 was not prescribed. On the issue of compensability of the illness: The Court agreed with the acting referee that the nature of Cirilo Andres' work could have directly caused or at least aggravated his chronic peptic ulcer. The respondent employer failed to present substantial evidence to disconnect the illness from the employment, thus failing to discharge its burden of proof. The presumption of compensability, arising from the uncontroverted fact that the chronic peptic ulcer and disability supervened in the course of employment, became conclusive due to the employer's failure to rebut it. On the issue of controversion: The Supreme Court found that the employee's right to compensation was not effectively controverted by the respondent employer. The employer failed to timely comply with Section 37 of the Workmen's Compensation Act by not filing the Employer's Report of Accident or Sickness within 14 days from the occurrence or 10 days from knowledge of the illness. The report was filed only on February 15, 1971, which was too late. This delay resulted in the renunciation of the right to controvert the claim, barring all defenses and constructively admitting the compensability of the illness.
Main Doctrine
The Supreme Court reversed the Workmen's Compensation Commission's decision, holding that the claim for disability benefits was for disability compensation, not death benefits, and thus the two-year period for death benefits was inapplicable. The Court also found that the claim had not prescribed as the reckoning point was the date of effective disability, not the onset of illness, and that the employer's failure to timely controvert the claim barred all defenses.