Facts:

On March 17, 1975, Domingo Lopez, a 64-year-old shop teacher at Balayan Elementary School in Balayan, Batangas, filed a claim for compensation against the Republic of the Philippines (Bureau of Public Schools) with the Workmen's Compensation Commission, Regional Office No. 5, San Pablo City. Lopez claimed that he had to stop working on December 21, 1973, due to illnesses including rheumatism, hypertension, and pulmonary tuberculosis, which he alleged were contracted or aggravated by the nature of his work. The claim was supported by an Employer's Report of Accident or Sickness from Mr. Pacifico Dimailig, the school principal, which stated that Lopez's right to compensation was not contested, and a Physician's Report from Dr. Ireno Sison, who diagnosed Lopez with hypertension, chronic rheumatism, and pharyngitis.

On September 25, 1975, Lopez was advised to submit further evidence, which he complied with by filing an affidavit on October 2, 1975. A conference ...

Facts:

Background of the Case:

• Domingo Lopez, a 64-year-old shop teacher at Balayan Elementary School in Batangas, filed a claim for compensation under the Workmen's Compensation Law on March 17, 1975. He alleged that he was forced to stop working on December 21, 1973, due to illnesses (rheumatism, hypertension, and pulmonary tuberculosis) that he claimed were caused or aggravated by the nature of his work.

Employer's Response:

• The Employer's Report of Accident or Sickness, completed by the school principal, stated that the employee's right to compensation was not controverted. A Physician's Report by Dr. Ireno Sison diagnosed Lopez with hypertension, chronic rheumatism, and pharyngitis.

Procedural History:

• The case was forwarded to the Director of Public Schools and the Office of the Solicitor General. Despite multiple notices for conferences and submission of counter-affidavits, the respondent (Bureau of Public Schools) failed to appear or respond.
• On November 24, 1975, an award was issued in favor of Lopez, granting him compensation for medical expenses, disability benefits, attorney’s fees, and administrative fees.

Motion for Reconsideration:

• The Office of the Solicitor General filed a motion for reconsideration, arguing that the illnesses were not compensable under the Workmen's Compensation Act and that no causal link between the illnesses and Lopez's work was established.
• The motion was denied, and the case was elevated to the Workmen's Compensation Commission, which reversed the award, ruling that the illnesses were not compensable or work-related.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Failure to Controvert: Under the Workmen's Compensation Act, failure to file a timely notice of controversion constitutes a waiver of the right to contest the claim on non-jurisdictional grounds. The employer's failure to controvert the claim within the prescribed period rendered the claim compensable by operation of law.
2. Presumption of Compensability: Section 44 of the Workmen's Compensation Act presumes that a claim is compensable if the illness supervenes during employment. The burden is on the employer to prove otherwise with substantial evidence, which the respondent failed to do.
3. Evidence of Disability: The approval of Lopez's optional retirement was deemed sufficient proof of his disability, as it indicated that he was physically incapable of continuing his work.
4. Public Policy: The forfeiture of the right to controvert is a statutory sanction designed to ensure compliance with the Act's requirements and protect the rights of laborers.

Conclusion:

The Supreme Court reinstated the award, ordering the respondent to pay Lopez for medical expenses, compensation benefits, attorney’s fees, and administrative fees. The decision emphasized the importance of timely controversion and the presumption of compensability under the Workmen's Compensation Act.