G.R. No. L-25756. January 24, 1975.
INSULAR LUMBER COMPANY, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION AND JOSE QUINTO, respondents.

FACTS

Jose Quinto was employed by Insular Lumber Company as a moulder since 1925, later promoted to capataz in 1950. On July 27, 1950, a company chest X-ray revealed he had far-advanced pulmonary tuberculosis. He was hospitalized, treated by the company physician, and resumed work. However, subsequent X-rays showed the illness persisted, leading to his discharge on May 10, 1952. Upon separation, he signed a cash voucher stating he had no further claims against the company.
On April 21, 1960, Quinto filed a formal notice of sickness and claim for compensation. The employer, in a letter-controversion dated July 20, 1960, denied the claim, arguing the illness was not work-related and that the claim was time-barred under Section 24 of the Workmen’s Compensation Act. The hearing officer awarded compensation, a decision affirmed by the Workmen’s Compensation Commission, though the amount was reduced to P3,000 under the old law applicable at the time of separation.

ISSUE

Whether the claim for compensation is barred due to: (1) late filing beyond the statutory period, and (2) the employee’s alleged waiver of claims via a separation voucher.

RULING

The Supreme Court affirmed the Commission’s decision, holding the claim was not barred. On the issue of prescription, the claim filed in 1960 for a 1950-1952 disability was indeed beyond the two-month period under Section 24. However, delay is not a bar if the employer had knowledge of the sickness and was not prejudiced by the delay. The company physician discovered the tuberculosis in July 1950, giving the employer immediate knowledge. The statutory notice requirement aims to afford the employer an early opportunity to investigate; this purpose was satisfied here as the company was aware from the outset. Citing Vda. de Calado vs. WCC, the Court ruled the employer did not suffer from the delay.
Furthermore, the employer’s right to controvert the claim was deemed waived. Under Section 45 of the Act, the employer must controvert the right to compensation within the prescribed period (on or before the fourteenth day of disability or within ten days from knowledge). The company’s letter-controversion in 1960 was filed nearly a decade late, constituting a waiver of its right to challenge the claim, as established in Pioneer Ceramics, Inc. vs. Samia.
Regarding the alleged waiver via the 1952 cash voucher, the Court declared it null and void. Section 7 of the Compensation Act expressly states any contract or device intended to exempt the employer from liability under the Act is invalid. Therefore, Quinto’s signature on the voucher did not constitute a valid renunciation of his statutory right to compensation. The award was thus upheld.