G.R. No. L-40175 August 31, 1978
REPUBLIC OF THE PHILIPPINES (OFFICE OF THE SOLICITOR GENERAL), petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and ANGEL COSTALES, respondents.

FACTS

The private respondent, Angel Costales, was employed as an assistant supply officer in the Office of the Solicitor General. In 1965, he was diagnosed with malignant hypertension and genitourinary disturbances. He continued working but suffered a stroke in 1971, diagnosed as severe hypertension and cerebral vascular accident, which caused paralysis. Due to this disability, his application for retirement was approved effective October 1, 1971. In 1972, Costales filed a claim for disability compensation benefits with the Workmen’s Compensation Commission.
The Office of the Solicitor General received the claim on June 22, 1972, and filed a notice of controversion on July 3, 1972. The Acting Referee awarded compensation to Costales. The petitioner elevated the case to the Commission, whose Chairman affirmed the award on April 4, 1974. The petitioner received this decision on April 8, 1974. It subsequently filed motions for extension of time and a motion for reconsideration. The Commission, however, declared the decision final and executory, ruling that the motion for reconsideration was filed out of time.

ISSUE

The primary issues were: (1) whether the Commission erred in declaring its decision final and executory; (2) whether Costales’s illness was compensable; and (3) whether the petitioner forfeited its right to controvert the claim.

RULING

The Supreme Court affirmed the Commission’s decision. On the procedural issue, the Court held that the petitioner’s motion for a first extension of time was sent by registered mail on April 18, 1974, within the reglementary period. The date of mailing is considered the date of filing. Therefore, the subsequent motion for reconsideration was timely, and the Commission erred in declaring its decision final on procedural grounds.
On the substantive merits, the Court ruled that the petitioner forfeited its right to controvert the claim. The employer, the Office of the Solicitor General, had knowledge of Costales’s ailment as early as 1965 and at the latest by his retirement in 1971. Despite this knowledge, it failed to file a notice of controversion within the period mandated by Section 45 of the Workmen’s Compensation Act. This failure constituted a renunciation, by operation of law, of all non-jurisdictional defenses, including the non-compensability of the illness.
Furthermore, the Court found that the illness—hypertension which culminated in a stroke—supervened during Costales’s employment. There was a rebuttable presumption under the law that the illness was work-related or aggravated by employment. The petitioner failed to present competent evidence to rebut this presumption. The fact of Costales’s retirement due to the disability solidified the compensable nature of his claim under the Act. The award of disability benefits, reimbursement for medical expenses, attorney’s fees, and administrative costs was upheld. The benefits were ordered paid to Costales’s legal heirs upon proper substitution.