GR L 42508; (June, 1979) (Digest)
G.R. No. L-42508 June 29, 1979
MARIA D. OBOR, in her own behalf and in representation of her minor children, PRIMITIVA OBOR and JOSEFINA OBOR, petitioners, vs. THE WORKMEN’S COMPENSATION COMMISSION, and REPUBLIC OF THE PHILIPPINES (Highway Engineer’s Office, Samar), respondents.
FACTS
Jesus Q. Obor, a supplies-checker for the Highway Auditor’s Office in Catbalogan, Samar, was killed on December 6, 1974, while performing his official duty of checking road right-of-way claims. His widow, Maria D. Obor, acting on the advice of the local Highway Auditor, filed a notice and claim for death compensation benefits with the Office of the Engineer’s Auditor of Samar on January 22, 1975. This office subsequently forwarded the claim to the Commission on Audit (COA).
On April 22, 1975, the COA returned the claim to the Highway Auditor, advising that the claimants should file their claim in accordance with the amended Labor Code. Maria D. Obor then forwarded the claim to the Workmen’s Compensation Unit in Tacloban City on June 2, 1975. The Acting Referee dismissed the claim, ruling it was filed after the statutory deadline of March 31, 1975, set by Presidential Decree No. 662. The Workmen’s Compensation Commission affirmed this dismissal, holding the claim was time-barred.
ISSUE
Whether the filing of the claim for death benefits with the Commission on Audit on January 22, 1975, constitutes substantial compliance with the statutory deadline for filing such claims.
RULING
The Supreme Court ruled in favor of the petitioners and set aside the dismissal. The legal logic centers on the doctrine of substantial compliance in the filing of claims. The Court held that the filing of the claim with the COA, an office without direct authority to act on workmen’s compensation claims, should be treated as having been filed with the appropriate agency since it was done within the period allowed by law. The Court cited its precedent in Corales v. Employees Compensation Commission, which established that a claim filed with an incorrect government office within the prescribed period is deemed filed on time with the proper agency. Here, the initial filing with the Highway Auditor and its subsequent routing to the COA occurred on January 22, 1975, well before the March 31, 1975 deadline. Therefore, the Acting Referee and the Commission erred in declaring the claim time-barred. The claim was referred to the proper office of the Ministry of Labor for a hearing on its merits.