Julia Reyes v. Workmen's Compensation Commission and Republic of the Philippines (Bicol University formerly Bicol Teacher's College)
REITERATIONFacts
The Antecedents: Julia Reyes, a teacher at Bicol Teacher's College (later absorbed by Bicol University), filed a claim for disability benefits in 1972 due to ailments diagnosed as "polyneuritis error of refraction; labyrinthitis; coronary insufficiency." She had been employed since 1920 and retired in July 1964 due to her condition, which she first felt in 1960 and worsened over time, causing dizziness, recurring headache, and blurring of vision. Her last salary was P328.60 monthly. Procedural History: The Bicol University initially filed an Employer's Report that did not controvert the claim. Subsequently, an amended report controverted the claim, alleging it was outside the Workmen's Compensation Act's coverage. The Acting Referee of Regional Office No. 5 awarded disability benefits, reimbursement for medical expenses, and attorney's fees. The Workmen's Compensation Commission reversed this decision, stating Reyes stopped working due to age, not sickness, and was not an employee of Bicol University at the time of absorption. A motion for reconsideration was denied, citing the proper remedy as a petition for review with the Supreme Court. The Petition: This case is a petition for review of the Workmen's Compensation Commission's decision.
Issue(s)
Whether the amended Employer's Report controverting the claim was valid. Whether the claimant's ailment was a compensable disease. Whether the claim was barred by prescription. Whether Bicol University assumed the obligations of Bicol Teacher's College regarding the claimant's rights. Whether the claimant is entitled to reimbursement for medical expenses. Whether the motion for reconsideration filed with the Commission was the proper remedy.
Ruling
The Supreme Court set aside the decision of the Workmen's Compensation Commission and ordered Bicol University to pay Julia Reyes P6,000.00 as disability benefits, reimburse her medical expenses supported by receipts, pay P600.00 as attorney's fees, and pay P61.00 as administrative fee to the successor of the Workmen's Compensation Commission.
Ratio Decidendi
On the validity of the amended Employer's Report: The Court affirmed the Acting Referee's ruling that the amended Employer's Report, filed more than 10 days after knowledge of the disability, was void. Citing previous rulings, the Court emphasized that an Employer's Report must be filed within 10 days from knowledge of the injury or accident, or 14 days from knowledge of the disability, to be considered valid under Sections 37 and 45 of Act No. 3428, as amended. The failure to controvert a claim within the prescribed period constitutes a waiver of all non-jurisdictional defenses, rendering the amended report null and void and preventing the employer from raising defenses. On the compensability of the ailment: The Court held that there was sufficient showing that the claimant's disability was caused by a compensable disease. The ailment supervened during her employment, triggering the presumption of compensability under Section 44 of the Workmen's Compensation Act. The burden shifted to the employer to prove that the ailment was not caused by the employment, a burden which the employer failed to discharge. The claimant also presented substantial evidence to support her claim. On the prescription of the claim: The Court found no merit in the contention that the claim was barred by prescription. The claimant had ten (10) years from the date the right of action accrued within which to file a claim. Since she retired on August 14, 1964, and filed the claim in 1972, less than ten (10) years had elapsed. This period is consistent with the principle that a claimant has a decade to file a claim from the accrual of the right of action. On the assumption of obligations by Bicol University: The Court clarified that the petitioner was never an employee of Bicol University in the strict sense of direct hiring, but her rights were protected. When Bicol University absorbed Bicol Teacher's College on September 22, 1970, it also assumed the obligations of the absorbed institution, including the claimant's accrued rights to benefits. Therefore, the claimant's right of action against Bicol Teacher's College was deemed included among the obligations assumed by Bicol University. On reimbursement of medical expenses: The Court affirmed the claimant's entitlement to reimbursement for medical expenses, provided they were supported by proper receipts. This aligns with the provisions of Section 13 of the Workmen's Compensation Act, which allows for reimbursement of medical expenses incurred due to work-related illnesses or injuries. On the procedural remedy: The Court found the contention that the decision had become final due to the filing of a motion for reconsideration instead of a petition for review to be without merit. The Court emphasized that substantial justice should not be sacrificed for technicalities, indicating a preference for resolving the substantive merits of the case rather than dismissing it on procedural grounds.
Main Doctrine
The failure to controvert a claim within the period prescribed by law constitutes a waiver of all non-jurisdictional defenses. Furthermore, the presumption of compensability applies to illnesses contracted during employment, shifting the burden to the employer to prove otherwise. A claim for disability benefits under the Workmen's Compensation Act is not barred by prescription if filed within ten years from the accrual of the right of action, and the successor entity assumes the obligations of the absorbed institution.