Lacson v. Secretary of Labor
REITERATIONFacts
The Antecedents: Felicidad Lacson Ramirez, an employee of the Development Bank of the Philippines (DBP) for nineteen years, became ill with diabetes mellitus, pyelonephritis with uremia, and hypertension. She stopped working on July 11, 1973, and filed a claim for compensation. Pending adjudication, she died on October 4, 1973, leaving her mother, Maria Lacson, as her sole heir. Maria Lacson subsequently filed a claim for death compensation, asserting that her daughter's illnesses were contracted during and aggravated by her employment. Procedural History: An Acting Referee initially awarded death benefits, burial expenses, medical expenses, and attorney's fees to Maria Lacson. The respondent employer, DBP, moved for reconsideration, which was denied, and the case was elevated to the Workmen's Compensation Commission (WCC). The WCC reversed the Acting Referee's decision, holding that the deceased's illnesses were idiopathic and not compensable under the Workmen's Compensation Act. The petitioner moved for reconsideration of the WCC's decision, which was denied by the Secretary of Labor, acting as head of the Compensation Appeals and Review Staff (the successor to the WCC). The Petition: Maria Lacson filed a petition for review, arguing that the respondents committed grave error by not finding that the employer failed to observe the formalities under Section 45 of Act No. 3428 and by not finding that the illness was aggravated by her employment. The petition highlights the employer's failure to timely controvert the claim, asserting that this failure constitutes a waiver of non-jurisdictional defenses. It further contends that the deceased's illnesses supervened during her employment and were aggravated by the nature of her work, invoking the presumption of compensability which the employer failed to rebut with substantial evidence.
Issue(s)
Whether the respondent employer failed to observe the formalities under Section 45 of Act No. 3428, as amended, in controverting the claim. Whether the illness of the late Felicidad Ramirez was aggravated by her employment.
Ruling
The Supreme Court vacated and set aside the decision of the respondent Commission and the order of the Secretary of Labor, ordering the Development Bank of the Philippines to pay Maria Lacson death compensation benefits, reimbursement for burial expenses, reimbursement for medical expenses, and attorney's fees.
Ratio Decidendi
On the failure to observe formalities in controverting the claim: The Court held that the employer, Development Bank of the Philippines (DBP), failed to timely and effectively controvert the claimant's right to compensation. Felicidad Ramirez was entitled to disability benefits as early as July 11, 1973, when her illnesses prevented her from working for more than three days. Under Section 3 of the Workmen's Compensation Act, the employer was obligated to file a notice of illness and manifest its intention to controvert the claim. The DBP did not show compliance with Sections 37 and 45 of the Act regarding the filing of notice of initial illness and death, and controverting the right to compensation within the prescribed period of fourteen days from disability or death, or ten days from knowledge thereof. The employer had knowledge of the illnesses even before July 11, 1973, as the deceased consulted the company physician, and was furnished a copy of the Notice of Injury or Sickness and Claim for Compensation on the same day she stopped working. Knowledge of the death on October 4, 1973, was also evident from the Service Record. The controversion filed on December 4, 1973, was beyond the reglementary period. The Court reiterated its ruling that failure to comply with statutory requirements within the prescribed period constitutes a renunciation of the employer's right to controvert, resulting in the waiver of all non-jurisdictional defenses, including the non-compensability of the claim. The fact that the petitioner did not raise the timeliness of the controversion before the Acting Referee was deemed of no moment, as this statutory right cannot be waived, especially by a non-lawyer. On the aggravation of illness by employment: The Court found it undisputed that the illnesses of Felicidad Ramirez supervened in the course of her employment. She was presumably in good health when she started working in 1954, and only in July 1973, after nineteen years of service, was she diagnosed with diabetes mellitus, pyelonephritis with uremia, and hypertension. The work as Loan Examiner and Analyst involved physical and mental strain, and it was during her long service that symptoms manifested. The attending physician, Dra. Helen Paulino-Abundo, stated in her report that the illnesses were aggravated by the nature of her work. These incontrovertible facts invoked the rebuttable presumption that the illnesses arose out of or were aggravated by the employment, placing the burden on the employer to prove otherwise. Since the employer presented no evidence to rebut this presumption, the Commission was unjustified in absolving the employer, making the presumption of compensability conclusive. The Court cited previous rulings that it is not necessary for employment to be the sole factor in the aggravation of an illness; it is enough that it contributed even in a small degree. The Court also noted that mere opinions of doctors cannot prevail over the presumption of compensability mandated by law, especially when the employer relies solely on such opinions without presenting substantial evidence to rebut the presumption. The Court affirmed that an employee is freed from the burden of proving causation or aggravation when the illness or death supervenes in the course of employment.
Main Doctrine
The failure of an employer to timely and effectively controvert a claim for compensation benefits under the Workmen's Compensation Act results in the waiver of all non-jurisdictional defenses, including the defense of non-compensability of the claim. Furthermore, when an illness supervenes in the course of employment, there is a rebuttable presumption that the illness arose out of or was aggravated by the nature of the employment, and the employer bears the burden of proving otherwise.