GR 44271; (September, 1977) (Digest)
G.R. No. L-44271 September 22, 1977
FLORENCIO CUYNO, JR., representing the estate of his father FLORENCIO CUYNO SR., petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and MUNICIPALITY OF ABUYOG, LEYTE, respondents.
FACTS
Florencio Cuyno, Sr. served as Municipal Treasurer of Abuyog, Leyte. On the evening of January 27, 1968, while working overtime in his office, he was suddenly stricken ill, brought to the hospital, and died minutes later. The resident physician diagnosed the cause of death as “acute heart failure, severe, secondary to extensive myocardial infarction which could have been brought off by the stress and strain inherent to the performance of his duties.” Petitioner Florencio Cuyno, Jr., representing his father’s estate, filed a claim for death compensation. The Acting Referee of the Workmen’s Compensation Unit dismissed the claim, finding no evidence linking the illness to his employment. This decision was affirmed by the defunct Workmen’s Compensation Commission. The petitioner argued that the decision was rendered prematurely before he could fully present his evidence and that the employer failed to seasonably controvert the claim.
ISSUE
Whether the death of Florencio Cuyno, Sr. is compensable under the Workmen’s Compensation Act.
RULING
Yes, the death is compensable. The Supreme Court reversed the Commission’s decision. The legal logic is twofold. First, the physician’s report, which attributed the fatal heart attack to the “stress and strain inherent to the performance of his duties,” constitutes prima facie evidence that the death was work-connected. Under the Workmen’s Compensation Act, when an employee dies in the course of employment, the presumption of compensability applies. Any doubt regarding the cause of illness must be resolved in favor of the claimant. The Commission erred in disregarding this medical evidence and in stating there was no record of treatment or physician’s report.
Second, the employer, the Municipality of Abuyog, forfeited its right to contest the claim due to its failure to comply with mandatory procedural requirements. Section 44 of the Act requires an employer to submit a report of the accident and to controvert the claim within a specific period. The municipality did not file any report or controvert the claim within the prescribed period following the employee’s death. This failure constitutes a waiver of all non-jurisdictional defenses, including the lack of causal connection, and renders the claim compensable as a matter of law. Consequently, the employer is liable for death benefits, burial expenses, attorney’s fees, and administrative fees.