Capinpin v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioners, parents of the deceased Mario Capinpin, filed a claim for compensation after their son died on February 15, 1969, while cutting timber using a mechanized chainsaw owned by respondent Greenwood Sawmill, Inc. The deceased was allegedly hit by a falling tree. Petitioners alleged the company had provided P1,200.00 for burial and incidental expenses. Procedural History: The claim was filed on July 23, 1969. Hearings were scheduled and reset multiple times, with issues arising regarding notice and venue changes. Summons were issued on January 8, 1970. Respondent Economic Insurance Co. filed a notice to controvert, alleging the claim was filed beyond the reglementary period. Respondent Greenwood Sawmill Co. filed its report controverting the claim, asserting it was not the employer, the claim had prescribed, and the company was dissolved on February 15, 1969. The hearing officer dismissed the case on June 29, 1970, for lack of merit, citing the claimant's failure to present proof of employment. A motion for reconsideration was denied, and the Workmen's Compensation Commission (WCC) affirmed the dismissal on December 24, 1975. The Petition: Petitioners sought review of the WCC decision, raising issues of denial of due process, prescription of the claim, and valid controversion.
Issue(s)
Whether or not the order dated June 29, 1970, is null and void for lack of due process. Whether or not the notice of death and claim was filed out of time. Whether or not the claim was validly controverted, considering the existence of an employer-employee relationship and the liability of the respondents.
Ruling
The Supreme Court set aside the decision of the respondent Commission and ordered respondent Greenwood Sawmill, Inc. to pay petitioners P6,000.00 as death benefits with interest, P600.00 as attorney's fees, and administrative costs. The respondent company was absolved from paying burial expenses due to prior advances.
Ratio Decidendi
On the issue of denial of due process: The Court found that the claimant was deprived of his day in court because he was not properly notified of the change in venue for the hearing on June 29, 1970. The records did not support the hearing officer's finding of numerous postponements requested by the claimant, nor did they show minutes of crucial hearings. The sudden change of venue without notice, coupled with the haste in issuing the dismissal order on the same day, indicated a denial of due process. The Court reiterated that notice, to be meaningful, must be both as to time and place, and lack of notice constitutes denial of due process, citing Shell Company of the Philippines vs. Enage and Insular Bank of Asia vs. Borromeo. On the issue of prescription: The Court held that failure to file the notice and claim for compensation within the reglementary period is not jurisdictional, and the statutory right to compensation prescribes in ten years, citing St. Anne's Hospital vs. WCC, Balanga vs. WCC, Canonero vs. WCC, and Romero vs. WCC. Therefore, the claim was not filed out of time. On the issue of valid controversion, employer-employee relationship, and liability: The Court stated that the failure of the respondent company to controvert the claim within the statutory limits of Section 24 of the Workmen's Compensation Act is deemed a waiver or renunciation of its non-jurisdictional defenses. This failure meant that petitioners were entitled to an outright award. The Court found no substantiation for the respondent company's allegation that the deceased was not its employee, citing an affidavit from a co-worker. The Court found no liability on the part of Plating Uy or Economic Insurance Co., limiting liability to respondent Greenwood Sawmill, Inc., and imposed an additional liability in the form of interest due to the company's bad faith.
Main Doctrine
A claimant's failure to file a notice and claim for compensation within the reglementary period is not jurisdictional, and the statutory right to compensation prescribes in ten years. Furthermore, the failure of an employer to controvert the claim within the statutory limits is deemed a waiver of non-jurisdictional defenses.