G.R. No. L-17015; April 29, 1961
GEORGE H. EVANS, ETC., petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and NATALIA ARGUELLES VDA. DE NAVAL, respondents.

FACTS

Natalia Arguelles Vda. de Naval filed a claim for death benefits under the Workmen’s Compensation Act against the Dahican Lumber Company following the death of her husband, Fabian Naval. The company denied liability, asserting that Naval had been laid off on July 31, 1952, and died on August 10, 1952, when no employer-employee relationship existed. The company later entered receivership, with George H. Evans appointed as receiver. Evans, through counsel, suggested to the Workmen’s Compensation Commission that a hearing be conducted to determine the claim’s merits, after which any award could be submitted to the receivership court. The Commission’s referee then issued an order directing the parties to appear before the Public Defender in Daet, Camarines Norte, when summoned.
The Public Defender conducted a hearing on January 28 and 30, 1956, without notifying Evans or his counsel to appear. Subsequently, on April 25, 1956, the referee rendered a decision awarding compensation to the claimant. Evans received no notice of this decision or any subsequent proceedings. It was only on June 12, 1959, that Evans received a letter from the Commission demanding payment of the award, prompting him to protest that he had never been notified of the decision or given an opportunity to present evidence.

ISSUE

Whether the Workmen’s Compensation Commission’s proceedings and decision are valid despite the petitioner not receiving notice of the hearing and the subsequent decision.

RULING

The Supreme Court set aside the Commission’s decision and resolution, ruling that the proceedings were null and void for violating the petitioner’s right to due process. The legal logic centers on the fundamental requirement of notice and hearing. While the referee’s initial order directed parties to appear before the Public Defender “when summoned,” the Commission failed to actually summon Evans or his counsel to the January 1956 hearing. Consequently, Evans was deprived of any opportunity to participate, present evidence, or cross-examine witnesses. This deprivation of his day in court rendered all subsequent proceedings, including the ex parte decision, legally ineffective.
The Court rejected the Commission’s argument that the employer’s failure to formally controvert the claim within the statutory period resulted in an admission of liability. The records showed the company seasonably denied liability upon receiving the claim, citing the termination of employment prior to death, which constituted a sufficient controversion. Furthermore, the Court found no merit in Evans’ separate claim that, as a receiver, he could not be sued without the appointing court’s permission. By previously suggesting that the Commission hear the claim to determine its merits, Evans had effectively submitted to the Commission’s jurisdiction. The case was remanded to the Commission for proper proceedings with due notice to all parties.