G.R. No. 48576 August 11, 1989
MANSUETA T. TIBULAN, MARIO TIBULAN and ULYSSES TIBULAN, petitioners, vs. HON. AMADO G. INCIONG, Acting Minister of Labor, and LUZON STEVEDORING CORPORATION, respondents.

FACTS

Pedro Tibulan worked as a Barge Patron for Luzon Stevedoring Corporation from 1930 until his death in 1965. In 1963, he began suffering from hypertension and heart ailments. On December 23, 1965, he returned home with chest and stomach pains, was hospitalized, and died the next day from myocardial infarction and hypertension. In 1966, his widow Mansueta filed a claim under the Workmen’s Compensation Act. Her then-counsel, without her authority, filed a motion to dismiss the claim, which was granted. Mansueta, through new counsel, sought reconsideration and relief, but these were denied. The case remained dormant for years until petitioners refiled their claim in 1974.
In 1975, the Acting Referee awarded compensation benefits to petitioners. The employer, Luzon Stevedoring, appealed to the Workmen’s Compensation Commission. The Commission reversed the award, ruling that petitioners failed to prove a causal connection between Pedro’s work and his death and that their evidence of relationship to the deceased was insufficient. Petitioners’ motions for reconsideration were denied by the Secretary of Labor, prompting this petition.

ISSUE

The primary issue is whether the Workmen’s Compensation Commission erred in reversing the Acting Referee’s award of death benefits to the petitioners.

RULING

The Supreme Court granted the petition and reinstated the Acting Referee’s award. The Court emphasized that the Workmen’s Compensation Act is social legislation designed for the working class’s benefit, requiring a liberal interpretation in favor of claimants. Under the Act, when an illness supervenes during employment, it is presumed compensable unless the employer proves otherwise. Here, Pedro’s hypertension and heart disease, which led to his death, manifested during his 35-year employment. The employer failed to rebut the statutory presumption of compensability, as it did not present substantial evidence to show the illness was not work-related or was due to a pre-existing condition.
Regarding the timeliness of petitioners’ motion for reconsideration before the Commission, the Court held it was filed within the reglementary period under the Workmen’s Compensation Act, considering the excusable negligence of their counsel who was on official military duty when the decision was received. On the merits, the employer’s failure to timely controvert the claim with the Commission and to submit supporting evidence constituted a waiver of non-jurisdictional defenses, including the defense of non-compensability. The Commission’s reversal was erroneous for disregarding the statutory presumption and the employer’s waiver. The Court also awarded legal interest on the compensation from the date of the original award and attorney’s fees.