Faicol v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Federico M. Faicol was an employee of the Republic of the Philippines (National Irrigation Administration) for 39 years, retiring at age 63 due to disability from hypertension with renal complication. His work involved planning, directing, and supervising irrigation systems, requiring travel and exposure to environmental elements. As early as January 3, 1960, he was diagnosed with hypertension, and by 1968, his personal physician certified partial disability due to recurring hypertension. His condition was aggravated over the years, leading to chronic nephritis by the time of his retirement on January 12, 1974. Procedural History: Petitioner filed a claim for compensation benefits under the Workmen's Compensation Act. The claim was dismissed by Regional Office No. 4 of the Department of Labor for being filed beyond the reglementary period. The Workmen's Compensation Commission affirmed this dismissal, stating that since petitioner retired optionally at age 63, he was entitled to retirement benefits equivalent to compulsory retirement and thus did not suffer loss of earning power, and that hypertension is not an occupational disease. Petitioner's subsequent appeal to the Supreme Court was initially dismissed for non-payment of fees, but he was later allowed to file a petition for review on certiorari. The Petition: Petitioner sought review of the decision of the Workmen's Compensation Commission, arguing that his claim was filed within the reglementary period and that his illness was compensable and aggravated by his employment.
Issue(s)
Whether the petitioner's claim for compensation was filed within the reglementary period. Whether the employer failed to controvert the claim within the prescribed period. Whether the petitioner's optional retirement at age 63 due to disability disqualifies him from receiving compensation benefits. Whether the petitioner's illness (hypertension and chronic nephritis) 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 National Irrigation Administration to pay petitioner P6,000.00 as compensation benefits, reimburse medical expenses, pay attorney's fees of P600.00, and pay administrative fees of P61.00.
Ratio Decidendi
On the issue of the reglementary period for filing the claim: The Court found that the petitioner's claim was indeed filed within the reglementary period. Evidence, including a registry receipt postmarked March 31, 1975, and a certification from the postmaster, established that the registered mail containing the claim was mailed on March 31, 1975. Applying the rule that the date of mailing is considered the date of filing, the claim was deemed filed on time, even if received by the Regional Office on April 8, 1975. This principle was supported by previous rulings of the Court, such as in Canete vs. Insular Co. Inc., which held that the date of mailing shown by the post-office registry receipt is the date of filing. On the issue of failure to controvert the claim: The Court ruled that the respondent employer failed to controvert the claim within the period prescribed by Section 44 of the Workmen's Compensation Act. The Act requires employers to file a notice of controversion within 14 days from the date of disability or 10 days after knowledge thereof. The employer's report of sickness, which contained its controversion, was submitted on March 5, 1975, approximately 21 days after the petitioner's notice of injury and claim filed on February 12, 1975. This delay constituted a waiver of the right to controvert and a renunciation of all defenses, including the defense that the claim is not compensable, as established in prior cases like Simeon A. Canonero vs. WCC and Romero vs. WCC. On the issue of optional retirement and loss of earning power: The Court found the respondent Commission's ruling erroneous. It held that availing of optional retirement under Commonwealth Act 660, as amended, implies a finding of physical incapacity to render sound and efficient service, as per Memorandum Circular No. 133 of the Office of the President. Therefore, the petitioner's disability was already established upon approval of his optional retirement, and he remained entitled to disability benefits under the Workmen's Compensation Act. The argument that optional retirement at age 63 negates loss of earning power was rejected. On the compensability of the illness: The Court determined that the petitioner's illness arose out of and was aggravated in the course of his employment. Medical certifications indicated partial disability due to recurring hypertension since 1960, and aggravation of the sickness leading to hypertension with kidney complication by the time of retirement. The Court reiterated the rebuttable presumption of compensability for illnesses that supervene during employment, citing Simeon A. Canonero vs. WCC and Leopoldo Lorenzo vs. WCC. Since the employer failed to present substantial evidence to disprove the connection between the illness and employment, the illness remained compensable. The Court also noted that even if the cause of the ailment is unknown, its occurrence during employment sustains the presumption of compensability.
Main Doctrine
The failure of an employer to controvert a claim for compensation within the prescribed period constitutes a waiver of the right to controvert and a renunciation of all defenses, including the defense that the claim is not compensable. Furthermore, optional retirement due to physical incapacity implies disability, making the illness compensable under the Workmen's Compensation Act.