G.R. No. L-45768 May 12, 1978
DEMETRIO D. MOLET, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and REPUBLIC OF THE PHILIPPINES (Department of Health), respondents.

FACTS

Demetrio D. Molet, an administrative officer at the Provincial Health Office in Virac, Catanduanes, filed a claim for compensation benefits under the Workmen’s Compensation Act. He alleged suffering from recurrent attacks of hypertension since 1953, with the latest occurring on December 7, 1974. His claim was supported by medical reports, including one from the Compensation Rating Medical Officer which evaluated his condition and indicated a “Temporary Total Disability: one year B-occurrence.” The employer, the Department of Health, did not controvert the claim, and the Provincial Health Officer’s report stated the sickness was contracted “while in discharge of his duties.”
The Acting Referee dismissed the claim, ruling that Molet failed to demonstrate any physical disability or impairment of earning capacity since he remained in government service. Molet appealed this order. However, his appeal was initially filed with the Office of the President, with copies furnished to the Solicitor General, the Secretary of Labor, and the Acting Referee. The Workmen’s Compensation Commission (WCC) affirmed the dismissal, not on the merits, but on a procedural ground. The WCC held that the appeal was filed with the wrong forum and, consequently, the Referee’s order had become final and executory.

ISSUE

Whether the Workmen’s Compensation Commission erred in dismissing the appeal on the sole ground that it was filed with the wrong forum, thereby refusing to review the merits of the claim.

RULING

Yes. The Supreme Court reversed the decision of the Workmen’s Compensation Commission. The Court held that while the appeal was technically filed with the Office of the President, copies were duly furnished to the Solicitor General and the Secretary of Labor, who was then the Chairman of the WCC. This substantial compliance with the procedural requirement for perfecting an appeal was sufficient. The Commission should have treated the appeal as duly filed and proceeded to review the case on its merits.
On the merits, the Court found the claim compensable. The employer’s failure to controvert the claim within the statutory period constituted a waiver of all non-jurisdictional defenses, including the issue of compensability. Furthermore, the medical evidence, particularly the report of the Compensation Rating Medical Officer which found a temporary total disability for one year, was conclusive. The Acting Referee’s finding of no disability was contradicted by this official medical evaluation. The law presumes, in the absence of substantial evidence to the contrary, that a claim is compensable when filed within the period. Therefore, Molet was entitled to compensation for temporary total disability. The Court ordered the respondent to pay Molet P3,540.00 as compensation, reimburse medical expenses, pay attorney’s fees, and cover the administrative fees.