GR L 24073; (January, 1968) (Digest)
G.R. No. L-24073 January 30, 1968
PAMPANGA SUGAR MILLS, petitioner, vs. REGINA GALANG VDA. DE ESPELETA, PEDRO P. PELAEZ, as hearing referee of the Workmen’s Compensation Commission, and BENITO MACROHON, as Provincial Sheriff of Rizal, respondents.
FACTS
Petitioner Pampanga Sugar Mills seeks to enjoin the enforcement of a writ of execution issued by respondent Pedro P. Pelaez, a hearing referee of the Workmen’s Compensation Commission, to enforce a compensation award in favor of respondent widow, Regina Galang Vda. de Espeleta, for the death of her husband, a deceased employee of the petitioner. The petitioner’s defenses were that the claim was filed two years and six months after the death, beyond the two-month reglementary period under Section 24 of the Workmen’s Compensation Act, and that the disease (Cerebral Infarction due to Internal Hemorrhage caused by Hypertension) was not work-connected. The petitioner also alleged that its petition for review of the award was not filed on time due to the excusable neglect of its counsel’s messenger. The Workmen’s Compensation Commission rejected the defense of prescription, finding that the petitioner had made advance payments (medical/hospital assistance, P200 for funeral expenses, and P150 as financial help) which constituted an advance payment and recognition of the right to compensation, thus condoning non-compliance with Section 24. The Commission also noted the petitioner’s failure to report the death or to controvert the claim within the statutory period, which constituted a renunciation of its right to controvert and a constructive admission that the claim was compensable.
ISSUE
Whether the petitioner’s failure to controvert the claim for compensation within the reglementary period bars it from raising the defense that the claim was filed out of time.
RULING
Yes. The petition for certiorari and mandamus is denied, and the preliminary injunction is lifted. The Supreme Court held that the petitioner’s failure to controvert the claim is fatal to its defense of prescription. The failure to file the required controversion within the statutory period constitutes a renunciation of the right to challenge the claim, thereby waiving by operation of law any defense to the validity or reasonableness of the claim, including the defense of prescription. This principle is well-established in jurisprudence, including cases where claims were filed several years after the cause of action accrued. The Court found it unnecessary to rule on the petitioner’s plea regarding excusable neglect for the late filing of its petition for review, as the award must be sustained due to the failure to controvert. Costs are imposed on the petitioner.