G.R. No. L-29455 September 30, 1975
REGAL AUTO WORKS, INC., petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and AUGUSTA HERNANDEZ, respondents.

FACTS

The case involves a claim for death compensation filed by Florencia Hernandez Francisco, widow of the deceased employee Bernardo Francisco, against his employer, Regal Auto Works, Inc. Bernardo Francisco, employed as a collector, died on October 5, 1964, from ailments including hypertension and a perforated ulcer. The claimant filed her claim for compensation on December 14, 1964. The employer, however, only filed its notice of controversion on December 28, 1964, which was beyond the statutory period prescribed by Section 45 of the Workmen’s Compensation Act.
The Acting Referee and the respondent Workmen’s Compensation Commission both found that the employer’s controversion was filed late. The Commission noted that from the date of death on October 5, 1964, to the filing of the controversion on December 28, 1964, a period far exceeding the 14-day statutory limit had elapsed. The employer contested the award, arguing the merits of the claim, but the Commission ruled that the late controversion was fatal to its defense.

ISSUE

Whether the employer’s failure to file a timely notice of controversion under Section 45 of the Workmen’s Compensation Act precludes it from disputing the compensability of the claim.

RULING

Yes. The Supreme Court affirmed the decision of the Workmen’s Compensation Commission, ruling that the employer’s late controversion was fatal to its defense. The legal logic is anchored on the plain and mandatory language of Section 45 of the Workmen’s Compensation Act, which requires an employer to file a notice of controversion either on or before the fourteenth day of disability or within ten days after knowledge of the accident or sickness. Failure to comply with this requirement constitutes a waiver of the right to contest the claim, including defenses such as non-compensability or late filing of the claim itself.
The Court, citing established jurisprudence such as Victorias Milling Co., Inc. v. Workmen’s Compensation Commission and La Mallorca v. Workmen’s Compensation Commission, emphasized that the absence of a timely controversion renders the claim compensable beyond challenge. This rule is designed to ensure the expeditious delivery of benefits to injured workers or their heirs, in line with the act’s remedial purpose. Since the employer’s controversion was filed beyond the 14-day period from the employee’s death, it lost any legal basis to oppose the award. The Court found no reason to disregard the factual findings of the Commission and thus upheld the compensation award in favor of the claimant’s heir, Augusta Hernandez.