G.R. No. L-42767 July 25, 1978
Justino Pascua, petitioner, vs. Workmen’s Compensation Commission and Sanz Steel R.B.M., respondents.

FACTS

Justino Pascua filed a claim for disability compensation against his employer, Sanz Steel R.B.M., alleging he contracted pulmonary tuberculosis and fistula en anu during his employment as a painter, incapacitating him from work since October 18, 1973. The employer received the notice of claim on November 27, 1974, but failed to file an employer’s report or otherwise controvert the claim as required by law. Consequently, a Workmen’s Compensation Section Chief issued an outright award in favor of Pascua on January 28, 1975. The employer filed a motion for reconsideration only after receiving the award copy in March 1975.
A hearing on the motion was scheduled, but the employer failed to appear. The Acting Referee thus denied the motion and elevated the records. On December 13, 1975, the Workmen’s Compensation Commission reversed the award and dismissed the claim. The Commission reasoned that the evidence, primarily the notice of claim and a physician’s report, lacked substantial proof of disability. It also erroneously noted the claim was only for fistula en anu, not PTB, and cited payroll documents allegedly showing Pascua worked after his claimed disability date.

ISSUE

Whether the Workmen’s Compensation Commission erred in reversing the award and dismissing Pascua’s claim despite the employer’s failure to timely controvert the claim as required by law.

RULING

Yes. The Supreme Court reversed the Commission’s decision and reinstated the award. The legal logic is anchored on the mandatory nature of Section 45 of the Workmen’s Compensation Act. An employer must controvert a claim within the prescribed period; failure to do so constitutes a renunciation of the right to challenge the claim, barring the employer from presenting any defense. The employer here undisputedly failed to comply, having received the notice in November 1974 but filing no controversion.
The Commission’s justification for dismissal was legally flawed. First, it incorrectly stated the claim was only for fistula en anu, ignoring the notice which explicitly listed “fistula & t.b.” Second, it relied on payroll documents attached to the employer’s motion for reconsideration. However, since the employer waived its right to present evidence by failing to appear at the scheduled hearing, these documents were not properly offered in evidence and thus had no evidentiary value. Finally, the legal presumption that an illness arising during employment is compensable stood unrebutted due to the employer’s default. The Commission’s rush to clear its docket before its abolition led to a denial of a legitimate claim.