G.R. No. L-20381, December 24, 1963
FILIPINO PIPE AND FOUNDRY CORPORATION, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION, JOSE A. NALDO, WENCESLAO GOZON and GUILLERMO HIWATIG, respondents.

FACTS

Petitioner Filipino Pipe & Foundry Corporation was the employer of respondent Guillermo Hiwatig, who filed a claim for compensation due to temporary total disability from a work-related accident on May 3, 1961. Notice of the accident was given to the company physician on the same date. Hiwatig formally filed his claim with the Regional Office of the Department of Labor on October 11, 1961. The petitioner failed to file an answer or controvert the claim within the ten-day reglementary period provided by law.
Consequently, on February 5, 1962, the Regional Commissioner issued an award in favor of Hiwatig, deeming the claim uncontroverted due to the employer’s failure to contest it timely. The petitioner received a copy of this award on February 16, 1962. It subsequently filed a “petition for new hearing” on March 5, 1962, which was denied. Later, on July 11, 1962, it filed a “Petition for relief from judgment,” which was also denied. The petitioner then instituted this original action for certiorari, alleging the award was made without notice and hearing, constituting a denial of due process.

ISSUE

Whether the Workmen’s Compensation Commission committed a grave abuse of discretion in issuing the award without a formal hearing, thereby denying the petitioner due process of law.

RULING

The Supreme Court denied the petition and dismissed the case. The legal logic is clear and multi-faceted. First, under Section 45 of Act No. 3428 (the Workmen’s Compensation Act), an employer’s failure to controvert a claim within ten days from notice constitutes a renunciation of the right to contest it; the claim is deemed admitted. The petitioner’s excuse—that its president’s secretary delayed delivering the claim—does not absolve it, as the employer must bear the consequences of its own employee’s negligence. This statutory renunciation extinguished any right to demand a hearing.
Second, procedural rules barred relief. The “petition for new hearing” was filed more than fifteen days from notice of the award, rendering the award final and executory under Section 50 of Act No. 3428 . Furthermore, this petition functionally resembled a motion for relief from judgment under Rule 38 of the Rules of Court but was fatally defective for lacking a required affidavit of merit. The subsequent “Petition for relief from judgment” was filed well beyond the 60-day period allowed by Rule 38.
Finally, the petitioner had a plain, speedy, and adequate remedy through an ordinary appeal from the award and the subsequent denial orders, making certiorari inappropriate. The Commission did not act without or in excess of jurisdiction; it correctly applied the law’s consequences for the petitioner’s default. Thus, no denial of due process occurred, as the statutory scheme itself provided the legal effect of the petitioner’s inaction.