G.R. No. L-26763 December 26, 1969
Republic of the Philippines (Philippine Navy), petitioner, vs. Workmen’s Compensation Commission and Jose Erolin, respondents.

FACTS

Respondent Jose Erolin was employed as a dockman-rigger by the Philippine Navy from January 16, 1952, to May 18, 1962. His duties involved heavy manual labor. In March 1962, while at work, he began coughing and had a hemoptysis. An X-ray examination on May 18, 1962, revealed he had minimal, bilateral tuberculosis, and the company physician advised him to stop working. He filed a claim for compensation on July 18, 1962. The Philippine Navy did not controvert the claim within the statutory period, though it attempted to do so months later. A hearing officer initially dismissed the claim for lack of causal connection. After a series of petitions, the Chairman of the Workmen’s Compensation Commission reversed this decision on June 8, 1965, awarding Erolin disability compensation, reimbursement for medical expenses of P168.00, and future medical assistance. This decision was affirmed by the Commission en banc. The Navy paid the disability compensation up to the maximum of P4,000.00 but did not reimburse the P168.00. On February 25, 1966, Erolin filed a motion directly with the Commission seeking additional reimbursement of P1,248.90 for medical expenses incurred from 1962 to October 1965. The Commission granted this motion. The Philippine Navy petitioned for review, arguing the Commission had no original jurisdiction over the motion, that it was granted without a formal hearing, and that Erolin failed to give the required notices under the Workmen’s Compensation Act.

ISSUE

1. Whether the Workmen’s Compensation Commission had jurisdiction to entertain and grant Erolin’s motion for additional medical reimbursement filed directly with it.
2. Whether the grant of the motion without a formal hearing was proper.
3. Whether Erolin’s failure to give the notices required under Section 13 of the Workmen’s Compensation Act barred his claim.

RULING

1. Yes, the Commission had jurisdiction. The power to hear and decide compensation claims is under the exclusive jurisdiction of the Workmen’s Compensation Commission. While referees in regional offices have original jurisdiction, the Commission itself is not stripped of original jurisdiction. Section 49 of the Act authorizes hearings to be held before the Commissioner or any referee. Furthermore, Erolin’s motion was essentially a petition for the implementation of the Commission’s final decision of June 8, 1965, which the Commission had the power to entertain and grant.
2. Yes, the grant without a formal hearing was proper. The Philippine Navy had notice of Erolin’s illness on May 18, 1962, but did not file a notice to controvert the claim within the 14-day statutory period. Consequently, the claim was deemed uncontroverted. For an uncontroverted claim, neither a formal hearing nor a formal award is necessary to establish the right to collect. Since the motion sought implementation of a final decision, defenses based on procedural lapses, like failure to give notice under Section 13, were deemed waived. The Commission found the claimed amount reasonable, and the Supreme Court agreed.
3. No, the failure to give notice did not bar the claim. The defense of failure to give the notice required under Section 13 of the Act was waived because the employer (the Navy) did not timely controvert the claim. The right to question the validity and reasonableness of the reimbursement was therefore barred.
Disposition: The Supreme Court remanded the case to the Workmen’s Compensation Commission. The Court held that the award of P168.00 in the June 8, 1965, decision was final and settled reimbursement for expenses up to that date. Erolin was entitled only to reimbursement for medical expenses incurred after June 8, 1965. The Commission was directed to determine that amount and issue the corresponding payment order.