Mesina v. Republic
REITERATIONFacts
The Antecedents: Carlos Mesina, employed as Clerk II by the Bureau of Customs since July 1948, filed a claim for disability compensation benefits on August 8, 1974. He alleged contracting pulmonary tuberculosis, peptic ulcer, rheumatoid arthritis, and coronary insufficiency in the course of his employment. He stopped working on October 2, 1972, due to these ailments. Procedural History: The Acting Referee of the Department of Labor ruled in favor of Mesina, ordering the Bureau of Customs to pay disability compensation and medical expenses. The Republic of the Philippines (Bureau of Customs) appealed to the Workmen's Compensation Commission (WCC), which reversed the Acting Referee's decision and dismissed the case. Mesina then filed a petition for review with the Supreme Court. The Petition: Mesina sought to set aside the WCC decision, arguing that the WCC gravely erred in not considering the timeliness of the Solicitor General's motion for reconsideration, in disregarding the findings of the Compensation Rating Medical Officer, in ignoring his medical evidence, and in failing to apply Section 45 of Act No. 3428.
Issue(s)
Whether the ailments of Pulmonary Tuberculosis, peptic ulcer, Rheumatoid Arthritis, and coronary insufficiency are compensable under the Workmen's Compensation Act given that they supervened during the petitioner's employment. Whether the respondent's failure to timely controvert the claim constitutes a waiver of the right to challenge its compensability.
Ruling
The Supreme Court set aside the decision of the Workmen's Compensation Commission and ordered the respondent, Republic of the Philippines (Bureau of Customs, Department of Finance), to pay the petitioner, Carlos Mesina, the sum of P6,000.00 as disability compensation benefits, P2,470.60 as reimbursement for medical expenses, P600.00 as attorney's fees, and the successor of the Workmen's Compensation Commission the sum of P61.00 as administrative fee.
Ratio Decidendi
On Issue 1: The Supreme Court held that the illnesses are compensable because it is undisputed that they supervened during the petitioner's employment with the Bureau of Customs. Applying Section 44 of the Workmen's Compensation Act and the ruling in Justiniano v. Workmen's Compensation Commission, the Court emphasized that a disputable presumption exists that the claim is compensable once the illness occurs during employment. This legal presumption relieves the claimant of the duty to prove the cause of the illness, as the law assumes it arose out of or was aggravated by the employment. The burden of proof is shifted to the employer to establish that the illness is non-compensable with substantial evidence. In this case, the respondent offered no evidence to rebut the presumption, rendering the petitioner's claim valid. Therefore, the Commission's requirement for the petitioner to present further substantial evidence was a misapplication of the law. On Issue 2: The Court ruled that the respondent's failure to file an answer or controvert the claim resulted in the renunciation of all non-jurisdictional defenses. Citing Section 45 of the Workmen's Compensation Act and Lominog Dinaro v. Workmen's Compensation Commission, the Court clarified that timely controversion is essential for an employer to dispute a claim. Since the Bureau of Customs did not file an answer despite being notified, it lost the right to challenge the factual basis of the petitioner's disability. The Workmen's Compensation Commission's reversal, based on the alleged weakness of the petitioner's medical evidence, was improper because the respondent had already waived its right to contest those facts. The procedural default by the Bureau of Customs made the Acting Referee's findings on disability and medical expenses final as against non-jurisdictional challenges. Consequently, the petitioner was entitled to the maximum disability benefits and reimbursement of medical expenses as supported by the record.
Main Doctrine
The presumption of compensability under the Workmen's Compensation Act shifts the burden of proof to the employer to establish that the illness is non-compensable. Failure to controvert the claim or present evidence to rebut the presumption and the claimant's evidence renders the claim compensable.