G.R. No. L-46579 April 28, 1980
JULIA REYES, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and REPUBLIC OF THE PHILIPPINES (BICOL UNIVERSITY FORMERLY BICOL TEACHER’S COLLEGE), respondents.

FACTS

Julia Reyes, a public school teacher since 1920, retired in July 1964 from the Bicol Teacher’s College due to ailments diagnosed as polyneuritis, error of refraction, labyrinthitis, and coronary insufficiency. She filed a claim for disability benefits in 1972. The respondent Bicol University, which had absorbed the Bicol Teacher’s College, initially filed an Employer’s Report that did not controvert the claim. However, it later submitted an amended report attempting to controvert it, alleging the claim was not covered by the Workmen’s Compensation Act and that Reyes retired due to age and was never its employee.
The Acting Referee awarded Reyes disability benefits, medical reimbursement, and attorney’s fees. The Workmen’s Compensation Commission reversed this decision, ruling her retirement was due to age, not disability, and that she was not an employee of Bicol University as she retired before the absorption of the college’s personnel. Reyes’ motion for reconsideration was denied on procedural grounds, prompting this petition for review.

ISSUE

The primary issues were: (1) whether the employer’s belated controversion of the claim was valid; (2) whether Reyes’ ailments were compensable and arose from her employment; and (3) whether Bicol University could be held liable for a claim arising from employment with its predecessor institution.

RULING

The Supreme Court reversed the Commission’s decision and reinstated the award. On the first issue, the Court held the amended Employer’s Report was void for being filed beyond the statutory period. The failure to timely controvert constitutes a waiver of all non-jurisdictional defenses, including the defense of non-compensability.
On compensability, the Court applied the presumption under the Workmen’s Compensation Act that a claim is compensable when the illness supervenes during employment. Reyes’ ailments manifested during her service, and she presented substantial evidence linking them to her work. The burden to disprove this causal link shifted to the employer, which it failed to do. The Commission’s finding that she retired due to age was erroneous, as the medical evidence established her retirement was due to disabling sickness.
Regarding liability, the Court ruled Bicol University assumed the obligations of the absorbed Bicol Teacher’s College. Reyes’ right of action, which accrued within the ten-year prescriptive period, was among these obligations. Finally, the Court dismissed procedural objections, emphasizing that substantial justice should prevail over technicalities. The University was ordered to pay disability benefits, reimburse medical expenses, and pay attorney’s and administrative fees.