GR 43536; (August, 1978) (Digest)
G.R. No. L-43536 August 31, 1978
SOLEDAD R. RUIVIVAR, petitioner, vs. THE WORKMEN’S COMPENSATION COMMISSION, REPUBLIC OF THE PHILIPPINES (BUREAU OF PUBLIC SCHOOLS), respondents.
FACTS
Soledad R. Ruivivar, a public school teacher employed by the Bureau of Public Schools for eighteen years, ceased working on September 2, 1971, due to toxic goiter and rheumatoid thyroid heart. She filed a claim for disability compensation with the Workmen’s Compensation Unit, Regional Office No. 5. The employer’s report did not controvert the claim, admitting her employment, salary, sickness, and disability. The Regional Office awarded her disability benefits and medical reimbursement. The Bureau of Public Schools, through the Solicitor General, later petitioned for relief from judgment, arguing the Regional Office lacked jurisdiction because the Solicitor General was not served a copy of the notice and claim.
ISSUE
Whether the Regional Office No. 5 acquired jurisdiction over the claim despite the alleged lack of service of the notice and claim on the Office of the Solicitor General.
RULING
The Supreme Court ruled in favor of the petitioner, reinstating the award. The legal logic centered on the nature of the Workmen’s Compensation Act as social legislation to be liberally construed in favor of labor. The Court held that the procedural requirement for service on the Solicitor General, as outlined in operational manuals, cannot defeat the substantive right of an employee to compensation, especially when the employer had already submitted a report admitting the factual basis of the claim and registering non-controversion. Citing Dinero vs. Workmen’s Compensation Commission, the Court emphasized that failure to transmit a copy to the Solicitor General does not nullify jurisdiction over the state agency, as such a technicality should not be an instrument of injustice. The employer’s admission and failure to present contrary evidence triggered the presumption of compensability, which the petitioner sufficiently corroborated with evidence that her illness was work-related. Thus, the Workmen’s Compensation Commission erred in absolving the respondent based on a procedural lapse. The decision prioritized the constitutional guarantee of social justice and the directive to resolve all doubts in favor of the worker.