G.R. No. L-40174 October 11, 1977
PEDRO ILINGAN, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and PHILIPPINE NATIONAL RAILWAYS, respondents.

FACTS

Petitioner Pedro Ilingan was employed by respondent Philippine National Railways in various capacities, ultimately as a station agent, until he stopped working on April 1, 1967, upon reaching the age of 63, and filed for optional retirement. On April 27, 1970, he filed a claim for disability benefits with the Department of Labor, alleging work-related illness. The respondent employer filed its report controverting the claim on September 7, 1970. The acting labor referee of Regional Office No. IV rendered a decision on September 4, 1972, awarding compensation benefits to Ilingan.
The respondent employer appealed to the Workmen’s Compensation Commission. In its decision dated January 30, 1975, the Commission reversed the labor referee’s award, denying Ilingan’s claim. The Commission disregarded medical evidence, including a physician’s report and a March 15, 1967 chest X-ray result with an impression of “PTB minimal right” and “chronic bronchial asthma,” which Ilingan presented to substantiate his claim that his illness supervened during his employment.

ISSUE

The primary issues were whether the Workmen’s Compensation Commission erred in: (1) not applying the presumption of compensability under the Workmen’s Compensation Act; and (2) not ruling that the employer’s failure to file a timely controversion resulted in a waiver of its right to contest the claim.

RULING

The Supreme Court reversed the decision of the Workmen’s Compensation Commission and reinstated the award. The legal logic is anchored on two fundamental principles of the Workmen’s Compensation Act. First, under Section 44 of the Act, there exists a legal presumption that a claim is compensable if the illness supervened during employment. The burden to disprove this presumption by substantial evidence lies with the employer. Here, the respondent employer failed to present such substantial evidence to disconnect Ilingan’s pulmonary tuberculosis and bronchial asthma from his employment. The Commission’s disregard of the submitted medical reports was erroneous, as these constituted the best evidence available under the circumstances, especially since the employer did not exercise its right to have the claimant examined by its own physician.
Second, the employer failed to seasonably controvert the claim as mandated by Section 45 of the Act. The claim was filed on April 27, 1970, but the controversion was filed only on September 7, 1970, which was beyond the statutory period. This failure constituted a waiver by operation of law of the employer’s right to contest the claim on non-jurisdictional grounds. Consequently, the claim was deemed admitted. Given that the Workmen’s Compensation Act is social legislation designed for the worker’s relief, it must be liberally construed in favor of the employee. Thus, the employer was ordered to pay disability benefits, reimburse medical expenses, pay attorney’s fees, and administrative costs.