GR L 19051; (November, 1966) (Digest)
G.R. No. L-19051 November 23, 1966.
A. D. SANTOS, INC., doing business under the name and style of “CITY CAB”, petitioner, vs. ZOSIMO DABOCOL, respondent.
FACTS
On March 22, 1960, respondent Zosimo Dabocol, while driving a taxicab owned and operated by petitioner A.D. Santos, Inc. (City Cab), was stabbed by unidentified passengers and sustained injuries. He filed a claim for compensation with Regional Office No. 4 of the Department of Labor, which awarded him P2,207.53. Petitioner moved to set aside the award, alleging it was denied the opportunity to confront and cross-examine witnesses and to present evidence on its defense that no employer-employee relationship existed. The Regional Administrator denied the motion, citing that petitioner was given opportunities in conferences on September 13, September 25, and October 5, 1960, but failed to appear or fully present its case, and that uncontrovertible evidence (driver’s Identification Card, City Cab Damage Slips, affidavits of co-drivers) showed Dabocol was an employee. The Workmen’s Compensation Commission affirmed the award with modifications (P2,814.17 compensation, medical services, attorney’s fees, costs). Petitioner’s motion for reconsideration was denied, prompting this petition for review.
ISSUE
Whether petitioner was denied due process by not being given the opportunity to exercise its right to confront and cross-examine witnesses and to present evidence on its defense of no employer-employee relationship.
RULING
No. The Supreme Court affirmed the Commission’s decision. Petitioner was afforded reasonable opportunity to present its evidence and defense. The Regional Administrator’s order detailed that conferences were scheduled where petitioner’s counsel appeared but did not press the defense or present contrary evidence, and instead requested postponements and computations. The claim of no employer-employee relationship was deemed frivolous in light of the uncontroverted evidence presented by Dabocol. The Workmen’s Compensation Commission is not bound by technical rules of procedure, and due process was not sacrificed. The steps taken by petitioner were seen as merely for delay. The decision was affirmed in toto, with double costs against petitioner.