G.R. No. L-42817 November 29, 1978
ANGELES VDA. DE SISON, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and PHILIPPINE NATIONAL RAILWAYS, respondents.

FACTS

Petitioner Angeles Vda. de Sison, widow of the late Pedro Sison, filed a claim for death compensation under the Workmen’s Compensation Act. Her husband, Pedro Sison, served the Philippine National Railways from 1925 until June 1969, working his way up to First Class Conductor. He went on sick leave in June 1969 due to symptoms including abdominal pain, weight loss, and jaundice. He underwent surgery but died on June 25, 1969, from hepatic insufficiency, with contributing causes of cancer and liver cirrhosis. The respondent employer failed to controvert the claim within the statutory period.
Hearing Officer Pedro Pelaez, after receiving evidence, rendered a decision on March 3, 1975, granting the claim and awarding compensation. The employer filed a motion for reconsideration, which the claimant opposed as out of time, arguing the award was final. Strangely, the case was subsequently assigned to Acting Referee Benjamin Perez, who, after a hearing where the claimant failed to appear, dismissed the claim for lack of interest on August 27, 1975. The Workmen’s Compensation Commission affirmed this dismissal, stating it was unaware of Referee Pelaez’s prior decision.

ISSUE

Which of the two conflicting decisions—the award by Hearing Officer Pedro Pelaez or the dismissal by Acting Referee Benjamin Perez—should prevail?

RULING

The Supreme Court ruled in favor of the petitioner, reinstating the award by Hearing Officer Pedro Pelaez. The legal logic is grounded in procedural finality and the employer’s failure to comply with mandatory requirements. The decision of Referee Pelaez, rendered after a hearing on the merits, became final and executory due to the employer’s failure to timely and properly controvert the claim as required under Sections 37 and 45 of the Workmen’s Compensation Act. This failure constituted a waiver of all non-jurisdictional defenses, including the defense that the illness was not work-related.
Consequently, Acting Referee Perez and the Commission had no authority to review, reverse, or revive the case through a new order of dismissal. The Commission’s affirmation, based on a lack of awareness of the prior decision, was erroneous as the records clearly indicated the prior proceedings. On the substantive aspect, the Court upheld the compensability of the claim. The illness supervened during employment, giving rise to the rebuttable presumption that it arose out of or was aggravated by the work. The nature of Sison’s duties as a conductor, involving constant travel, jarring motions, and exposure to pollutants, contributed to the debilitation of his health. The employer failed to present substantial evidence to rebut this presumption. Therefore, the final and executory award was reinstated with a modification increasing the attorney’s fees.