G.R. No. L-42835. April 22, 1977.
LYDIA BUENAVENTURA, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and MIN NGAI (HUAT KEE) KNITTING & SHIRT FACTORY, respondents.

FACTS

Petitioner Lydia Buenaventura, a laborer, filed a claim for compensation on October 15, 1973, alleging she contracted hypertension in 1965, which incapacitated her from 1965 to 1973. The respondent company received notice but failed to file a controversion within the statutory period and did not appear at scheduled hearings. Consequently, the Hearing Officer awarded compensation benefits, citing the company’s failure to controvert as a waiver of its defenses under Section 45 of the Workmen’s Compensation Act.
The respondent company moved for reconsideration, arguing the claim had been previously settled and was not work-connected because the company was no longer operational. The Workmen’s Compensation Commission reversed the award. The Commission acknowledged the company’s failure to controvert was a fatal defect waiving non-jurisdictional defenses. However, it dismissed the claim on a ground not raised by the company, holding that hypertension, being merely a symptom and not an illness per se, required substantial evidence of work-connection or aggravation, which the claimant allegedly failed to provide.

ISSUE

Whether an uncontroverted claim for compensation must still be substantiated by the claimant with substantial evidence of work-connection after the employer’s failure to controvert within the statutory period.

RULING

The Supreme Court ruled in favor of the petitioner, setting aside the Commission’s decision. The legal logic is anchored on the mandatory nature of Section 45 of the Workmen’s Compensation Act. The employer’s failure to file a timely controversion constitutes a waiver of all non-jurisdictional defenses, including the defense that the illness is not compensable. This waiver is absolute and not conditional upon the claimant subsequently proving work-connection.
The Court emphasized that once an illness supervenes during employment, a rebuttable presumption arises that it arose out of or was aggravated by the employment. The burden to disprove this presumption shifts to the employer. By failing to controvert, the employer loses the right to challenge the claim’s compensability and is deemed to have admitted the allegations. The Commission therefore committed a grave abuse of discretion by injecting the requirement for the claimant to present substantial evidence after the company had waived its defenses. The Court condemned the Commission for absolving the employer on a ground not invoked and for disregarding the social justice principles underlying the compensation act. The Hearing Officer’s award was reinstated.