GR 30427; (June, 1973) (Digest)
G.R. No. L-30427, June 28, 1973
ROSENDO M. MANLAPAT, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and REYNALDO PADELARA, respondents.
FACTS
The case involves a claim for workmen’s compensation filed by respondent Reynaldo Padelara, a tailor employed at the R.M. Manlapat Tailoring Shop. On April 26, 1962, around 5:00 p.m., Padelara and two co-workers left the shop to take a snack at a nearby restaurant, a practice recognized by the employer. While eating, Padelara was suddenly assaulted by several unidentified persons. He managed to break free and ran towards the tailoring shop but was overtaken and further injured, suffering severe wounds including a depressed skull fracture. He was hospitalized and underwent surgery. The Workmen’s Compensation Commission awarded compensation to Padelara. The employer, petitioner Rosendo M. Manlapat, sought review, contending primarily that the hearing was vitiated by a denial of due process. He also raised two other objections: that the injuries did not arise out of and in the course of employment, and that the claim was filed beyond the two-month period prescribed by Section 24 of the Workmen’s Compensation Act.
ISSUE
The principal issue is whether the proceedings before the Workmen’s Compensation Commission violated the due process rights of the petitioner. Subsidiary issues are whether the injuries are compensable and whether the claim was timely filed.
RULING
The Supreme Court affirmed the award, finding no merit in the petitioner’s contentions. On the due process claim, the Court held it was devoid of adequate support and appeared to be an afterthought. The record showed that in his initial memorandum and subsequent motion for reconsideration before the Commission, the petitioner’s objections were squarely based on the lack of employer-employee relationship, the alleged non-compensability of the injuries, and the late filing of the claim. It was only in a later motion for reconsideration filed on June 5, 1968, that he tangentially raised the due process violation, acknowledging it was bolstered by recent Court rulings he had just come across. His own course of conduct indicated he was not initially impressed with the decisiveness of this claim. The Court, citing the cardinal primary rights in Ang Tibay v. CIR, emphasized that due process requires a decision supported by evidence presented at the hearing, but found no factual basis to sustain the petitioner’s bare assertion.
On the substantive issues, the Court upheld the Commission’s findings. The employment relationship was established. The injury was deemed to have arisen in the course of employment as the coffee-break period was recognized by the employer, making the trip to the restaurant an incident of employment. Regarding the filing period, the Court noted the petitioner failed to file a timely controversion of the claim as required by law, thereby waiving all non-jurisdictional defenses, including the alleged late filing. Consequently, the award was legally sound and must be sustained.