G.R. No. L-30979 October 26, 1973
PHILIPPINE GRAPHIC ARTS, INC., petitioner, vs. DIONISIO MARIANO and THE HONORABLE WORKMEN’S COMPENSATION COMMISSION, respondents.

FACTS

Dionisio Mariano worked as a composer for Philippine Graphic Arts, Inc. from 1958. His duties involved handling heavy metal molds, weighing three to six kilos, while standing at a table. He experienced periods of absence due to illness starting in 1963. On July 11, 1964, he consulted the company physician and was diagnosed with polyneuritis. Due to his condition, he tendered his resignation on July 13, 1964, which was accepted. He subsequently filed a claim for compensation benefits on October 1, 1964. The employer, petitioner herein, had filed an Employer’s Report of Accident or Sickness on August 5, 1964, indicating voluntary payments, but later moved to dismiss the claim on grounds of prescription.
The Acting Referee dismissed Mariano’s claim for lack of merit. On review, the Workmen’s Compensation Commission reversed the dismissal, finding the claim compensable. It ordered the employer to pay disability benefits, provide medical services, and pay costs. The employer’s motion for reconsideration was denied, prompting this petition for review, raising issues on controversion, the effect of resignation, and the compensability of an alleged idiopathic disease.

ISSUE

The primary issue is whether the employer’s failure to properly controvert the claim is fatal to its defense. Secondary issues involve the compensability of the illness and the legal effects of the employee’s resignation.

RULING

The Supreme Court denied the petition and affirmed the Commission’s decision. The ruling hinges on the employer’s fatal failure to comply with the mandatory requirement of controversion under Section 45 of the Workmen’s Compensation Act. The Court reiterated its consistent doctrine that failure to timely and effectively controvert a claim precludes the employer from raising any defense, including non-compensability. The petitioner’s act of filing an Employer’s Report did not constitute a valid controversion; a specific notice of controversion was required.
On the compensability of the illness, the Court deferred to the factual findings of the Commission, which are conclusive when based on substantial evidence. The Commission found that Mariano’s chronic mononeuritis, an ailment affecting his left side, was aggravated by the nature of his work involving heavy lifting and prolonged standing. Citing precedent, the Court held that where a pre-existing condition is aggravated by the employment, the resulting disability is compensable. The voluntary resignation of the employee does not negate this compensability if the disability arose during employment. The employer’s obligations under the Act are not extinguished by the employee’s resignation. Consequently, the award of disability benefits and medical services was upheld.