G.R. No. L-20504; March 31, 1965
NATIONAL DEVELOPMENT COMPANY, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and TOMAS MENDOZA, for himself, and as Guardian Ad-Litem of the minors DOLORES, LOLITA, PEÑAFRANCIA, FLOCERPIDA, and ROSALINDA, all surnamed MENDOZA, respondents.

FACTS

The claimant, Isabelina Mendoza (who died during the proceedings and was substituted by her heirs), began working for the National Development Company (NDC) on February 4, 1946, as physically fit. She operated various machines in the company’s textile mill. In 1954, she was treated by the company’s medical department for pulmonary tuberculosis. A chest X-ray on January 25, 1956, confirmed the disease. Upon the company physician’s instance, she was confined at the Quezon Institute from May 15 to August 30, 1956. After showing improvement and being certified fit by the company physician, she returned to work on December 17, 1956. On May 11, 1957, while performing her duties, she was hit by a machine and spat blood. A subsequent chest X-ray on May 13, 1957, revealed her tuberculosis was active and far advanced. She went on sick leave from May 13 to August 28, 1957, but on the latter date, she received a letter from NDC laying her off effective June 15, 1957. The Workmen’s Compensation Commission, finding her sickness work-connected, granted her claim for disability compensation. NDC received the written notice of injury and claim for compensation on September 5, 1960, which was over three years from the May 11, 1957, incident.

ISSUE

Whether the Workmen’s Compensation Commission erred in proceeding with and granting the claim, despite the claim being filed beyond the period prescribed in Section 24 of Act No. 3428 (the Workmen’s Compensation Act), thereby allegedly depriving the Commission of jurisdiction.

RULING

The Supreme Court affirmed the decision of the Workmen’s Compensation Commission. The Court held that NDC’s failure to file a notice of controversion of the employee’s right to compensation with the Commissioner “on or before the fourteenth day of disability” as required under Section 45, paragraph 2, of the Workmen’s Compensation Act, as amended, resulted in a statutory renunciation of its right to controvert the claim. This statutory bar applies to all defenses available to the employer, including the defense that the claim was filed beyond the period prescribed in Section 24. The obligation to file the notice of controversion under Section 45 is independent of the employee’s obligation to file a notice and claim under Section 24. Since NDC failed to comply with Section 45, it forfeited its right to raise any defense, including the alleged tardiness of the claim. Therefore, the Commission correctly proceeded with the case and granted the award.