G.R. No. L-16871; May 19, 1961
PHILIPPINE COTTON DEVELOPMENT CORPORATION, petitioner, vs. THE HON. WORKMEN’S COMPENSATION COMMISSION, ET AL., respondents.

FACTS

Rodrigo Sison, employed as a tool-keeper by the Philippine Cotton Development Corporation, spat blood while at work on November 14, 1957. After initial medical treatment in Cotabato, he was not readmitted to work and was instead given a pass to return to his hometown in Lingayen, Pangasinan. He subsequently filed a compensation claim with Regional Office No. 1 in Dagupan City. The company controverted the claim, arguing the illness was not work-related. It sought to transfer the hearing venue from Dagupan City to Dadiangas, General Santos, Cotabato, citing the inconvenience and expense for the company and its witnesses, as both employer and employee were based there during employment. The hearing officer denied the transfer motion.
The company then filed a motion to dismiss, supported by affidavits, which was also denied. After a postponement, the hearing was reset for May 12, 1959, in Dagupan City. The company filed a motion for reconsideration of the denial of its dismissal motion on May 8, 1959. When no company representative appeared on the May 12 hearing date, the officer proceeded ex parte and later rendered a decision awarding compensation to Sison. The company’s subsequent motions, including a request for hearing by interrogatories filed after the ex parte decision, were denied. The Workmen’s Compensation Commission affirmed the award.

ISSUE

The primary issues were whether the Workmen’s Compensation Commission erred in: (1) not granting the motion to transfer the venue of the hearing; and (2) allowing the hearing officer to proceed with an ex parte hearing.

RULING

The Supreme Court affirmed the Commission’s decision, finding no merit in the petitioner’s contentions. On the venue issue, the Court upheld the claimant’s option under Section 1, Rule 16 of the Rules of the Workmen’s Compensation Commission. The rule explicitly allows a claim to be filed and heard where the accident occurred, or where the claimant or the respondent resides, at the claimant’s option. The Court clarified that the claimant’s residence for this purpose is not restricted to his place of abode during employment. The rule’s design is to foster the convenience of the aggrieved laborer, and any potential inconvenience to the employer was a considered and acceptable aspect of the procedural framework aimed at protecting the worker’s welfare.
Regarding the ex parte hearing, the Court found no grave abuse of discretion. The record showed the hearing had been postponed at the company’s request. The hearing officer set the case for a specific date after denying the motion to dismiss. The company’s failure to appear on that set date justified proceeding ex parte to avoid further delay, in keeping with the law’s spirit of expediting compensation claims. The Court noted the company’s petition to hold the hearing through interrogatories was filed only after the ex parte decision had been rendered, which was too late. While acknowledging a dissenting Commissioner’s view on the fundamental right to a hearing, the Court held that under the circumstances, the hearing officer acted properly to dispose of the claim without undue delay.