Obor v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Jesus Q. Obor, a supplies-checker for the Bureau of Public Highways, was fatally attacked while performing his official duties on December 6, 1974. His widow, Maria D. Obor, and their minor children, Primitiva and Josefina Obor, subsequently filed a claim for death benefits. Procedural History: The initial claim was filed on January 22, 1975, with the Highway Engineering Auditor in Samar, who forwarded it to the Commission on Audit. The Commission on Audit returned the claim on April 22, 1975, advising that it be filed under the amended Labor Code. Maria D. Obor then sent the claim to the Workmen's Compensation Unit in Tacloban City on June 2, 1975. The Acting Referee dismissed the claim on October 1, 1975, for being filed after the March 31, 1975 deadline set by Presidential Decree No. 662. A motion for reconsideration was denied, but the case was elevated to the Workmen's Compensation Commission, which affirmed the dismissal. The Petition: Petitioners seek review of the Workmen's Compensation Commission's order affirming the dismissal of their claim. They argue that filing the claim with the Highway Engineering Auditor on January 22, 1975, constituted substantial compliance with the filing deadline, even though it was not initially filed with the designated Workmen's Compensation Unit. The core issue is whether this initial filing with an incorrect but related agency within the statutory period should be considered timely.
Issue(s)
Whether the filing of a claim for compensation with the Commission on Audit (COA), an office lacking authority to act on it, within the prescriptive period constitutes substantial compliance with the requirement that claims should be filed not later than March 31, 1975.
Ruling
The decision of the Workmen's Compensation Commission is set aside. The claim for death benefits is referred to the proper office of the Ministry of Labor for hearing on the merits.
Ratio Decidendi
On Issue 1: The Supreme Court held that the filing of the claim with the Highway Engineering Auditor on January 22, 1975, was a substantial compliance with the requirement that claims should be filed not later than March 31, 1975. Applying the ruling in Corales v. Employees Compensation Commission (G.R. No. L-44063), the Court declared that the fact that a claim was filed with the wrong office, such as the Commission on Audit (COA), does not militate against the claim. The Court reiterated that the filing of a claim in an office that has no authority to act on it can be treated as having been filed with the appropriate agency as long as it is filed within the period allowed by law. This doctrine, also supported by Pobre v. Workmen's Compensation Commission (77 SCRA 315), ensures that the right to compensation is not lost through technicalities or misdirection by government officials. The Court emphasized that since the petitioners filed their initial claim well before the March 31, 1975 deadline, the subsequent delay in forwarding it to the Tacloban unit should not be counted against them. Therefore, the Acting Referee and the Workmen's Compensation Commission (WCC) committed a reversible error in dismissing the claim for being filed out of time.
Main Doctrine
The filing of a claim for compensation with an office that has no authority to act on it can be treated as having been filed with the appropriate agency as long as it is filed within the period allowed by law, constituting substantial compliance.