GR L 18388; (June, 1963) (Digest)

G.R. No. L-18388; June 28, 1963
MANILA RAILROAD COMPANY, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION, ET AL., respondents.

FACTS

Cesarea A. Marcelo, representing herself and her minor children, filed a claim for death compensation on September 28, 1959, against the Manila Railroad Company. The claim arose from the death of her husband, Domingo Punzal, an assistant train conductor, who died of pulmonary tuberculosis on October 3, 1957. The claimants alleged the illness was contracted and aggravated by the nature of his duties, which included revising tickets, signaling, handling baggage, and working night shifts in all weather conditions. The company controverted the claim on multiple grounds, including that the illness was not work-related and that the claim had prescribed.
The hearing officer initially dismissed the complaint, finding the death arose from a cause independent of employment. On review, the Workmen’s Compensation Commission reversed this decision. Associate Commissioner Cesareo Perez ruled that the illness was indeed aggravated by Punzal’s work, ordering the company to pay death benefits, burial expenses, and attorney’s fees. The company’s motion for reconsideration was denied, prompting this petition for review.

ISSUE

Whether the claim for death compensation is barred due to the claimants’ failure to file it within the prescriptive period mandated by the Workmen’s Compensation Act.

RULING

The Supreme Court reversed the decision of the Workmen’s Compensation Commission, ruling that the claim was filed out of time and was therefore barred. The legal logic centers on strict compliance with the statutory condition precedent for filing a claim. Section 24 of Act No. 3428, as amended (the Workmen’s Compensation Act), explicitly required that a claim for compensation, in case of death, must be filed within three months from the date of death. The Court emphasized this requirement as a jurisdictional condition, not a mere procedural technicality.
The record indisputably showed that Domingo Punzal died on October 3, 1957, but the claim was filed only on September 28, 1959—more than twenty months after his death. This filing was well beyond the three-month statutory limit. The Court, citing its precedent in Luzon Stevedoring Company v. De Leon, held that non-compliance with this mandatory period for filing a claim operates as a bar to recovery. The provision establishes a condition precedent to the maintenance of any proceeding under the Act. Consequently, regardless of the merits concerning the work-connection of the illness, the claimants’ failure to adhere to the prescribed filing period was fatal to their case. The Court thus set aside the Commission’s award.