G.R. No. L-30428 February 7, 1973
DEVELOPMENT BANK OF THE PHILIPPINES, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION, ESTANISLAO SARTO, REFEREE, WORKMEN’S COMPENSATION UNIT RO6 and MELCHORA C. VDA. DE BRITANICO AND HER MINOR CHILDREN, respondents.

FACTS

Wilfredo Britanico, a records and mailing clerk for the Development Bank of the Philippines (DBP) in Naga City, died on October 29, 1967, from massive pulmonary hemorrhage, pulmonary Koch’s, and hypertension. His widow and eight minor children filed a claim for death benefits on December 5, 1967. The DBP, upon receiving the claim, submitted an Employer’s Report on January 4, 1968, wherein it admitted knowledge of Britanico’s illness on October 18, 1967, and his death on October 29, 1967, and manifested its controversion of the claim. Prior to a hearing, DBP filed a motion to dismiss, arguing it was not a government instrumentality covered by the Workmen’s Compensation Act, which was denied. The Supreme Court later affirmed DBP is a government instrumentality. At the hearing on April 8, 1968, claimants moved to declare the claim uncontroverted due to DBP’s late filing.

ISSUE

Whether the DBP forfeited its right to controvert the compensation claim for failure to comply with the mandatory periods under the Workmen’s Compensation Act.

RULING

Yes. The Supreme Court affirmed the Workmen’s Compensation Commission’s decision, holding that DBP forfeited its right to controvert. The legal logic is anchored on strict compliance with procedural deadlines under the Act. Section 45 requires an employer to controvert a claim within fourteen days after disability or within ten days after knowledge of the alleged injury, otherwise, all non-jurisdictional defenses are waived. DBP’s own Employer’s Report admitted it knew of the illness on October 18 and the death on October 29, 1967. Its controversion filed on January 4, 1968, was therefore indisputably beyond the statutory period. Furthermore, DBP failed to submit the report of injury “as soon as possible” as mandated by Section 37, constituting an independent ground for forfeiture of defenses. The Court rejected DBP’s excuse that it initially believed the ailment was minor, noting its resources allowed it to investigate the hospital records promptly. The failure to adhere to these mandatory provisions results in a conclusive presumption of compensability, rendering the claim uncontroverted. Thus, the award of death benefits to the claimants was proper.