GR 42675; (April, 1976) (Digest)
G.R. No. L-42675. April 30, 1976.
CONSOLACION M. TONSON, petitioner, vs. REPUBLIC OF THE PHILIPPINES (Bureau of Customs) and the WORKMEN’S COMPENSATION COMMISSION, respondents.
FACTS
Benedicto Tonson, a Senior Inspector at the Bureau of Customs, died on November 28, 1968, from portal cirrhosis. His widow, Consolacion Tonson, filed a death compensation claim on June 30, 1969. The Regional Office initially dismissed the claim for her non-appearance at a hearing. Upon a motion for reconsideration, the case was reopened. Hearings were conducted, and on October 31, 1975, the Acting Referee rendered a decision awarding death benefits and other expenses to the claimant’s estate and minor children.
Separately, the formal motion for reconsideration of the initial dismissal was erroneously elevated to the Workmen’s Compensation Commission. Unaware that the case had been reopened and decided by the Referee, the Commission, without conducting any hearing or receiving evidence, issued its own decision on December 31, 1975. It dismissed the claim on the merits, finding no causal relation between the illness and the employment.
ISSUE
Whether the Workmen’s Compensation Commission committed a denial of due process and a grave abuse of discretion in dismissing the claim without a hearing and without any evidence before it.
RULING
Yes. The Supreme Court set aside the Commission’s decision, ordering the execution of the Referee’s final and executory award. The Court held that the Commission’s action constituted a clear denial of due process. The right to a hearing, which includes the opportunity to present evidence, is a cardinal primary right in administrative proceedings. The Commission dismissed the claim on the merits despite having no evidentiary record before it, as all evidence had been presented to and evaluated by the Referee. The Commission’s justification—that it was in the “last stages of its legal existence”—was unacceptable, as expediency cannot override the fundamental right to be heard. A decision rendered without any supporting evidence is a nullity. The Office of the Solicitor General correctly joined the petition, conceding the error. The proper course for the Commission, had the motion been properly before it, was either to affirm the initial dismissal for lack of interest or to remand the case for hearing, not to decide the substantive merits without any factual basis.