National Housing Corporation v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: The underlying dispute concerns a claim for compensation benefits by Pedro de la Cruz, a former laborer for the National Housing Corporation, who contracted Hansen's disease during his employment. De la Cruz alleges he began working for the petitioner in 1961 and stopped in June 1972 due to his illness. The disease manifested with eruptions on his ears, nose, forehead, and body, along with finger deformities, leading to his discharge from employment. He was subsequently confined at the Central Luzon Sanitarium. Procedural History: Pedro de la Cruz filed a claim for compensation benefits with the Workmen's Compensation Commission. Despite being notified, the petitioner, National Housing Corporation, failed to file an Employer's Report and a notice of controversion as legally required. Initially, the claim was dismissed by a hearing referee for lack of evidence and failure to establish that the ailment arose from or was aggravated by his work. However, upon a motion for reconsideration, the case was reviewed by the Commission. The Commission reversed the dismissal, ordering the petitioner to pay P6,000.00 in compensation and P66.00 in administrative fees. The Petition: The National Housing Corporation filed this petition for review on certiorari with the Supreme Court, seeking to annul the decision of the Workmen's Compensation Commission. The petitioner argues that it was denied due process, claiming it had no prior knowledge or notice of the claim and was not furnished with any court processes, thus the lower offices lacked jurisdiction over its person and failed to provide an opportunity to be heard. Conversely, the petitioner asserts that the National Housing Corporation was aware of de la Cruz's illness, as its Personnel Office assisted him in filing for SSS benefits, and that the Commission's findings indicated proper notification was given, which the petitioner failed to controvert.
Issue(s)
Whether the Workmen's Compensation Commission acquired jurisdiction over the person of the petitioner and whether the petitioner was denied due process. Whether the petitioner lost its right to controvert the claim. Whether Hansen's disease is a compensable illness under the Workmen's Compensation Act.
Ruling
The Supreme Court affirmed the decision of the Workmen's Compensation Commission, ordering the petitioner to pay compensation benefits, attorney's fees, and administrative fees. The Court ruled that the petitioner had notice of the respondent's claim and failed to file a notice of controversion, thereby losing its right to challenge the claim and waiving all defenses.
Ratio Decidendi
On the issue of jurisdiction and due process: The Court held that the petitioner was duly notified or, at the very least, had notice of the private respondent's claim, evidenced by the fact that its Personnel Office assisted the respondent in applying for SSS benefits. This notice, coupled with the respondent's visible symptoms and the official reason for his discharge (contracting Hansen's disease), clearly indicated the petitioner's awareness of the illness. Consequently, the petitioner should have filed a notice of controversion as required by law. Its failure to do so meant it lost its right to challenge the claim, and thus, the WCC acquired jurisdiction and the petitioner cannot claim denial of due process for failing to avail of its opportunity to be heard by not controverting the claim. On the issue of the right to controvert the claim: The Court reiterated the principle that failure to file a notice to controvert the right to compensation within the period prescribed by Section 45 of the Workmen's Compensation Act, as amended, or within ten days after knowledge thereof, constitutes a waiver or renunciation of the right to controvert the claim. This waiver renders moot any question regarding the compensability, reasonableness, or validity of the claim, entitling the claimant to an outright award. The Court cited Garcia v. Workmen's Compensation Commission and Jesalva v. Workmen's Compensation Commission to support this ruling. On the compensability of Hansen's disease: The Court affirmed that Hansen's disease is compensable under the Workmen's Compensation Act if acquired or aggravated in the course of employment. The Court noted that medical evidence suggests Hansen's disease is a systemic disease caused by bacteria, and factors like sudden environmental changes and lessened body resistance can contribute to its development. Given that the respondent was medically cleared before employment and developed symptoms during his tenure, and considering his work as a laborer and the proximity of the petitioner's office to a sanitarium, it was concluded that the disease was acquired during and due to his employment.
Main Doctrine
Failure to file a notice of controversion within the prescribed period under the Workmen's Compensation Act, as amended, results in the loss of the employer's right to challenge the employee's claim, thereby constructively admitting its compensability and waiving all available defenses.