G.R. No. L-43309. October 23, 1982. SIMEON OLBES, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and PHILIPPINE FABRIKOID, INC., respondents.
FACTS

Petitioner Simeon Olbes was employed as a laborer by respondent Philippine Fabrikoid, Inc. On July 25, 1969, he contracted indirect inguinal hernia, which was reported as acquired or aggravated by the nature of his employment. He stopped working on September 14, 1971. The respondent company had knowledge of his illness through its representative, Manuel Go, and even defrayed his hospitalization and medical expenses. Olbes filed his claim for compensation on December 27, 1974. The company filed a motion to dismiss and a late controversion on April 1, 1975. The acting referee and subsequently the Workmen’s Compensation Commission dismissed the claim, finding that Olbes failed to present substantial evidence beyond the physician’s report to justify compensation.

ISSUE

Whether the petitioner’s claim for disability compensation due to hernia is compensable under the Workmen’s Compensation Act.

RULING

Yes, the claim is compensable. The Supreme Court reversed the Commission’s decision. The legal logic rests on two primary grounds. First, the presumption of compensability under the Act applies. The petitioner’s work as a laborer involved lifting heavy plastic products, a tedious manual job that clearly caused or aggravated his hernia. This causal connection is substantiated by the attending physician’s report, which stated the petitioner could resume work only if he did not carry very heavy objects. The Commission erred in dismissing the claim for lack of other proof, as the physician’s report itself, coupled with the undisputed nature of his work, established the work-connection.
Second, the respondent employer lost its right to contest the claim due to its failure to timely and properly controvert it. The company had knowledge of the illness but filed its notice of controversion only on April 1, 1975, far beyond the period mandated by Section 45 of the Workmen’s Compensation Act. Its prior act of paying the medical expenses constituted an acknowledgment of responsibility. The failure to comply with the statutory requirement for controversion is fatal to its defense and operates as a renunciation of its right to dispute the claim. Consequently, the petitioner is entitled to disability compensation, reimbursement for medical expenses, and the provision of necessary medical services.