Salanguit v. Republic
REITERATIONFacts
1. The Antecedents: Juan Salanguit filed a claim for compensation due to hypertension and rheumatoid arthritis, alleging these conditions were caused or aggravated by his employment with the Bureau of Public Highways. The employer initially did not controvert the claim, and the Acting Referee of Regional Office No. 4 awarded compensation. 2. Procedural History: The Acting Referee awarded P6,000.00 in compensation, P300.00 in attorney's fees, and P61.00 in administrative fees. The Republic of the Philippines, through the Office of the Solicitor General, received this decision on October 6, 1975, but filed a petition for relief from judgment on February 18, 1976, citing heavy workload. Despite the delay, the Workmen's Compensation Commission accepted the late filing, reversed the referee's decision, and dismissed the claim. 3. The Petition: This petition seeks review of the Workmen's Compensation Commission's decision. The petitioner argues that the Commission erred in accepting the late appeal from the Solicitor General, as workload is not a valid excuse for delay. Furthermore, the petitioner contends that the illness is presumed compensable, the employer waived defenses by not controverting the claim, and evidence supports the claim's merit, as found by the Acting Referee.
Issue(s)
Whether the Workmen's Compensation Commission erred in taking cognizance of the appeal filed by the respondent beyond the reglementary period. Whether the illness of the petitioner is compensable under the Workmen's Compensation Act.
Ruling
The Supreme Court set aside the decision of the Workmen's Compensation Commission and ordered the respondent, Republic of the Philippines (Bureau of Public Highways), to pay the petitioner disability compensation, reimburse medical expenses, pay attorney's fees, and pay administrative fees.
Ratio Decidendi
On the issue of late filing of appeal: The Court held that the Workmen's Compensation Commission erred in taking cognizance of the appeal filed by the respondent beyond the reglementary period. It is settled jurisprudence that volume and pressure of work in the Office of the Solicitor General is not a valid excuse for not filing an appeal or petition for relief on time. Furthermore, under the rules of the WCC, a petition for relief must be filed within thirty days after the petitioner learns of the decision or award sought to be set aside and not more than three months after such decision or award was entered. The OSG's petition was filed after four months, thus it should not have been given due course. On the compensability of the illness: The Court found the petition for review to be meritorious, even assuming, arguendo, that there was justification for the late filing. The record disclosed that the illness of Juan Salanguit supervened during his employment with the Bureau of Public Highways. Consequently, there is a disputable presumption that the claim is compensable under Section 44 of the Workmen's Compensation Act, as amended. This presumption relieves the claimant of the duty to prove causation, as it is legally presumed that the illness arose out of the employment. The burden of proof is shifted to the employer to establish that the illness is non-compensable. Moreover, the respondent had manifested that it was not controverting the claim, which is deemed a renunciation of all non-jurisdictional defenses. The claimant also presented evidence that his illness was a result of his employment, and the respondent failed to rebut the presumption or the evidence presented by the petitioner. The Acting Referee's findings, supported by substantial evidence, established that the claimant's work involved brain work, leading to mental stress and strain, which aggravated his hypertension. The attending physician's report also indicated that the claimant's blood pressure was aggravated due to strenuous work and the nature of his job.
Main Doctrine
The failure to controvert a claim for compensation under the Workmen's Compensation Act, coupled with the disputable presumption of compensability, shifts the burden of proof to the employer to establish that the illness is non-compensable. Volume and pressure of work in the Office of the Solicitor General is not a valid excuse for the late filing of an appeal or petition for relief.