GR L 16569; (May, 1964) (Digest)
G.R. No. L-16569. May 30, 1964.
PHILIPPINE ENGINEERING CORP., petitioner, vs. AMADO FLORENTINO and WORKMEN’S COMPENSATION COMMISSION, respondents.
FACTS
Amado Florentino was employed as a truck driver by Philippine Engineering Corporation since 1946. In 1952, an X-ray revealed he had pulmonary tuberculosis, leading to a six-month sick leave with pay. After returning to work, subsequent check-ups showed reactivation of his illness, for which the company provided medical aid. In 1956, he was reassigned to a lighter driving duty, but due to his persistent illness, he was laid off on February 20, 1958. On June 4, 1958, Florentino filed a claim for compensation under the Workmen’s Compensation Act.
The Hearing Officer awarded compensation to Florentino, ruling that the employer was barred from presenting controverting evidence due to its failure to file the required notice under Section 45 of the Act. The Workmen’s Compensation Commission, upon petition for review, reopened the case for the employer’s evidence but ultimately affirmed the award. The employer appealed, raising issues of timeliness, jurisdiction, and set-off of alleged loans.
ISSUE
The primary issues were: (1) whether Florentino’s claim was filed beyond the statutory period; (2) whether the Workmen’s Compensation Commission had jurisdiction; and (3) whether monetary advances given by the employer should be deducted from the compensation awarded.
RULING
The Supreme Court affirmed the Commission’s decision. On timeliness, the Court held the claim was not barred despite being filed years after the initial illness and months after dismissal. The legal logic is grounded on Section 24 of the Workmen’s Compensation Act, which provides that if the employer voluntarily makes compensation payments, the statutory filing period is no longer necessary. The Court upheld the Commission’s finding that the monetary assistance totaling P657.84 given by the company, part during the pendency of the case, constituted voluntary compensation payments or advance salaries, not mere loans. Thus, the late filing was excused.
On jurisdiction, the Court rejected the petitioner’s argument that Reorganization Plan No. 20-A abolished the Commission, noting this issue was not raised below and, substantively, the said Plan had already been declared unconstitutional. Finally, the Court found no error in not deducting the alleged loans from the award, as the Commission had correctly credited those amounts against separation pay awarded to Florentino in a related case. Costs were imposed on the petitioner.