Galindo v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioners are the widow and minor children of the late Proculo Galindo, who was employed by respondent Philippine Packing Corporation as a field laborer from October 22, 1949, until his death on August 24, 1971, due to "cancer of the liver with metastasis." Galindo was reportedly in good health and had never been absent from work. Procedural History: Respondent company filed an "Employer's Report of Accident or Sickness" on September 30, 1971, admitting knowledge of the sickness on July 31, 1971. Petitioners filed death compensation benefit claims on September 30, 1971. The Workmen's Compensation Unit (WCU) initially declared the claim non-controverted due to the company's failure to file a notice of controversion within the reglementary period. Despite a motion for reconsideration, the WCU denied it, citing the late submission of the Employer's Report. On September 26, 1972, the WCU issued an award in favor of the petitioners, finding the illness service-connected. The company moved for reinstatement of its right to controvert, alleging timely controversion on September 1, 1971. The WCU denied this, reiterating that the employer had knowledge of the ailment on July 31, 1971, making the September 1, 1971 notice beyond the statutory period. Upon appeal, the Workmen's Compensation Commission (WCC) reversed the WCU's award, holding that the controversion period for death benefits starts from knowledge of death, not disability, and that the September 1, 1971 notice was timely. The WCC also stated that cancer of the liver is not an occupational disease. The Petition: Petitioners sought a review of the WCC's decision, arguing that the company failed to controvert the claim within the prescribed period.
Issue(s)
Whether the respondent Commission erred in reversing the award of death compensation benefits. Whether the respondent company timely controverted the claim for death compensation benefits. Whether cancer of the liver can be considered a work-connected illness.
Ruling
The Supreme Court reversed and set aside the decision of the respondent Commission and reinstated the award of the former Workmen's Compensation Unit in favor of the petitioners.
Ratio Decidendi
On the reversal of the Commission's decision: The Court found merit in the petition, concluding that the WCC erred in reversing the award. The procedural lapse of the employer in failing to controvert the claim within the legal period was the primary basis for reinstating the WCU's award. The WCC's reasoning that the controversion period for death benefits starts from knowledge of death, not disability, was implicitly rejected by the Court's emphasis on the employer's knowledge of the sickness on July 31, 1971, and the statutory deadlines for controversion. On the timeliness of controversion: The Court held that the respondent company failed to controvert the claim within the period prescribed by Section 45 of the Workmen's Compensation Act (Act 3428). The company had knowledge of the deceased's illness on July 31, 1971. Even if the notice of controversion was filed on September 1, 1971, as alleged, this was 32 days from the date of knowledge, which is beyond the ten-day period provided by law. The Court clarified that the law requires controversion within fourteen days of disability or ten days of knowledge of the alleged accident or sickness. The subsequent death of the employee does not grant the employer more time to controvert. The liability of the employer attached earlier, making the claim's compensability, reasonableness, and validity beyond challenge due to the failure to controvert within the statutory period. This failure is considered a renunciation of the employer's right to controvert, which is fatal to any defense. On the compensability of cancer of the liver: The Court reiterated its ruling in Maria Cristina Fertilizer Corporation vs. WCC, et al. that cancer of the liver, even if not an occupational disease, may be deemed work-connected. The fact that the deceased's illness supervened during his employment, coupled with his prior good health and long service (almost 22 years as a field laborer), created a rebuttable presumption that the illness arose out of or was aggravated by his employment. The employer failed to present evidence to overcome this presumption.
Main Doctrine
Failure of an employer to controvert a claim for compensation within the period prescribed by Section 45 of the Workmen's Compensation Act (Act 3428) constitutes a renunciation of its right to controvert, rendering the compensability of the claim beyond challenge. The subsequent death of the employee does not extend the period for controversion.