Case Digest (G.R. No. L-43451)
Facts:
Petitioners Arcadio Capinpin and Candida M. Capinpin sought workmen’s compensation as parents of the deceased, Mario Capinpin, who died on February 15, 1969 while cutting timber in San Mariano, Isabela. They alleged that Mario was employed by Greenwood Sawmill, Inc. as a timber cutter when he was fatally hit by a falling tree while using a mechanized chainsaw.The claim was filed on July 23, 1969 and was denied by the hearing officer on June 29, 1970 for lack of merit, a denial affirmed by the Workmen’s Compensation Commission in its December 24, 1975 decision. Petitioners elevated the matter to the Supreme Court, imputing denial of due process and challenging other defenses raised below.
Issues:
- Whether the June 29, 1970 order dismissing the claim was null and void for lack of due process.
- Whether the notice of death and claim was filed out of time.
- Whether the claim was validly controverted.
Ruling:
The Court held that petitioners were deprived of their day in court Case Digest (G.R. No. L-43451)
Facts:
- Parties and capacities
- Arcadio Capinpin and Candida M. Capinpin filed a petition to review a decision of the Workmen’s Compensation Commission.
- Petitioners were the parents of the deceased Mario Capinpin.
- Respondents were the Workmen’s Compensation Commission, Piating Uy, Greenwood Sawmill, Inc., and Economic Insurance Co., Inc.
- Employment and death of the deceased
- Petitioners alleged that on the time of February 15, 1969, the deceased was employed by Greenwood Sawmill, Inc. as a timber cutter.
- Petitioners alleged that the deceased was cutting timber using a mechanized chainsaw owned by Greenwood Sawmill, Inc., when he was hit in the head by a falling tree and was crushed to death.
- Filing of the claim and initial scheduling
- Claimant Arcadio Capinpin filed the Notice and Claim for Compensation in Death Cases on July 23, 1969 against Greenwood Sawmill, Inc. and Alejandro Alvarez (the alleged concessionnaire of the forest area).
- Upon receipt, Hearing Officer Ramirez set the case for hearing on August 8, 1969.
- Alejandro Alvarez signed the proof of service of the Notice of Hearing; the manager of Greenwood Sawmill, Inc. refused to sign.
- The records contained no indication of what transpired during the scheduled hearing on August 8, 1969.
- The hearing was reset to November 7, 1969, and later to November 20, 1969.
- On November 20, 1969, only the lawyers for claimant and for respondent Alejandro Alvarez appeared.
- The lawyers mutually agreed to reset the hearing to December 2, 1969, with a change of venue from San Mariano, Isabela, to the municipal hall of Naguilian, Isabela, upon petition of claimant.
- The hearing was again reset to December 6, 1969, and the records did not mention venue in that later setting.
- Summons, respondents named, and omission of Alejandro Alvarez
- Summons were issued on January 8, 1970, requiring respondents to file an answer (Employer’s Report) within ten days from notice.
- The summons named: Mr. Fiating Uy, the manager of Greenwood Sawmill, Inc., the manager of Economic Insurance Co., Inc. in its Manila office, and the manager of Economic Insurance Co., Inc. at Tuguegarao, Cagayan.
- No mention was made of Alejandro Alvarez, who had been one of the original respondents.
- The records did not indicate why Alejandro Alvarez was later dropped.
- On January 8, 1970, an alias summons was issued to the same respondents.
- No returns of the original summons or the alias summons appeared in the records.
- Controversion and alleged defenses
- On January 20, 1970, Economic Insurance Co., Inc. filed a notice of intention to controvert, praying for dismissal on the ground that the claim was filed beyond the reglementary period in Section 24 of the Workmen’s Compensation Act.
- On March 30, 1970, Greenwood Sawmill Company filed its Employee’s Report of Accident or Illness, controverting the claim and asserting:
- The decision noted that the corporate dissolution defense appeared abandoned because pleadings signed by counsel for Respondent Greenwood Sawmill, Inc. did not mention dissolution or termination of business.
- Motions to dismiss and subsequent hearings
- On May 25, 1970, new counsel for the insurer filed a notice of appearance and a motion to dismiss dated May 8, 1970, praying for dismissal against the insurer on the ground that the respondent company was never insured with it.
- The case was calendared for June 1, 197...(Subscriber-Only)
Issues:
- Due process
- Whether the order dated June 29, 1970 was null and void for lack of due process due to alleged lack of notice, including the alleged sudden change of venue and the denial of a fair day in court.
- Timeliness of the claim
- Whether the notice of death and claim was filed out of time under the reglementary period in Section 24 of the Workmen’s Compensation Act.
- Validity of controversion
- Whether the claim was validly controverted within the statutory limits under Section 24 of the Workmen’s Compensation Act.
- Employee-employer relationship and effect of procedural defects
- Whether the existence of employer-employee relationship...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)