G.R. No. L-43434. May 25, 1979.
Juan Salanguit, petitioner, vs. Workmen’s Compensation Commission and Republic of the Philippines (Bureau of Public Highways), respondents.

FACTS

Juan Salanguit, employed as an Auditing Examiner II by the Bureau of Public Highways, filed a claim for compensation on July 12, 1974, due to hypertension and rheumatoid arthritis allegedly caused or aggravated by his employment. The employer, through an “Employer’s Report of Accident or Sickness,” signified it would not controvert the claim and acknowledged the illness occurred during his regular occupation. The Acting Referee of Regional Office No. 4, after a hearing, awarded Salanguit disability compensation.
The Republic, through the Office of the Solicitor General, received the Referee’s decision on October 6, 1975, but filed a petition to elevate the records for relief from judgment only on February 18, 1976, attributing the delay to the volume and pressure of work. The Workmen’s Compensation Commission nevertheless entertained the late appeal, reversed the Referee’s award, and dismissed the claim for lack of merit.

ISSUE

Whether the Workmen’s Compensation Commission erred in dismissing Juan Salanguit’s claim for compensation.

RULING

Yes. The Supreme Court reversed the Commission’s decision and reinstated the award. The legal logic proceeds from two key points: procedural timeliness and substantive compensability. Procedurally, the appeal by the Republic was filed out of time. The Court reiterated that the “volume and pressure of work” in the Solicitor General’s office is not a valid excuse for missing the reglementary period. Under the governing rules, a petition for relief must be filed within thirty days after learning of the decision and not more than three months after its entry.
Substantively, the claim is meritorious. The illness supervened during Salanguit’s employment, giving rise to the disputable presumption under the Workmen’s Compensation Act that the claim is compensable. This presumption shifts the burden of proof to the employer to show the illness is not work-related. The employer failed to discharge this burden. Crucially, by filing an Employer’s Report stating it would not controvert the claim, the Republic is deemed to have renounced all non-jurisdictional defenses. Salanguit also presented evidence, including a physician’s report, that his hypertension was aggravated by mental stress and strain from his auditing duties, which the employer did not rebut. Therefore, the compensability of the claim stands. The Court ordered the Bureau of Public Highways to pay Salanguit P6,000.00 as disability compensation, reimburse medical expenses, and pay attorney’s fees and an administrative fee.