G.R. No. L-34097 November 21, 1979
ROYAL MANUFACTURING COMPANY, petitioner, vs. ROSARIO GONZALES and the WORKMEN’S COMPENSATION COMMISSION, respondents.

FACTS

Perfecto Bilbao, a laborer for Royal Manufacturing Company, died on July 17, 1966. Despite a headache, he reported for work that day. While walking home on a bridge near the company compound, he swerved, fell into a river, and drowned. His widow, Rosario Gonzales, notified the company manager of the death the following day. However, she filed a formal claim for death benefits with the Workmen’s Compensation Commission only on August 2, 1967, over a year later.
The company, in its answer, sought to reinstate its right to controvert the claim, arguing it had no official knowledge of the death until August 1967 and that the claim was thus barred for being filed beyond the statutory period. The Acting Referee dismissed the claim. On review, the Workmen’s Compensation Commission reversed this dismissal, awarding death benefits, burial expenses, attorney’s fees, and costs. The company appealed, contending the death did not arise from employment, the claim was time-barred, and the decision lacked evidentiary support.

ISSUE

The primary issues were: (1) whether the claim for compensation was barred by prescription due to late filing; and (2) whether the employee’s death arose out of and in the course of his employment.

RULING

The Supreme Court affirmed the Commission’s award, rejecting the company’s defenses. On prescription, the Court held the claim was not barred. The law requires only that the employer has “knowledge of the accident,” not formal notice. The company’s cashier testified the death was common knowledge among people, and the widow had informed the manager a day after the incident. This actual knowledge excused any delay in formal filing. Crucially, the company failed to seasonably controvert the claim within ten days after gaining such knowledge. This failure constituted a statutory waiver of non-jurisdictional defenses, including prescription.
On compensability, the Court found the death work-connected. The Commission’s findings, supported by substantial evidence, noted Bilbao worked under a ceiling-less iron roof, performing strenuous shoveling, which could have aggravated a pre-existing condition like hypertension evidenced by his headache. His subsequent dizziness and fall on his way home from work was a direct and continuing effect of an ailment worsened by his working conditions. The Court emphasized that doubts regarding compensability under the Workmen’s Compensation Act must be resolved in favor of the claimant. The Commission’s factual findings being conclusive, the death was compensable.