Title
Malan Brothers Watchman Agency vs. Coan
Case
G.R. No. L-19019
Decision Date
Apr 29, 1963
The security guard's injury compensation claim is granted as the agency's late controversion leads to its automatic admission.
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Case Digest (G.R. No. L-19019)

Facts:

  • Malan Brothers Watchman Agency is the petitioner; Magdaleno Conanan and the Workmen's Compensation Commission are the respondents.
  • On November 6, 1959, Conanan, a security guard, was injured by an accidental discharge of his service pistol while on duty at Manila Bay Hosiery Mills, Inc.
  • Conanan filed a compensation claim on January 6, 1960, with the Department of Labor under Act No. 3428.
  • The claim was communicated to Malan Brothers on February 5, 1960, but the forms were returned unclaimed.
  • The claim was resent on March 29, 1960, and acknowledged by the agency's manager on April 4, 1960.
  • The agency submitted its response on October 3, 1960, contesting the claim but admitting to providing P350.00 as "voluntary help."
  • The Regional Administrator deemed the response untimely, leading to an award of P3,371.46 in favor of Conanan on October 12, 1960.
  • The agency failed to claim the award despite notifications and later filed a motion for reconsideration, which was denied.
  • The agency's appeal to the Workmen's Compensation Commission was dismissed on September 18, 1961, and a subsequent motion for reconsideration was also denied.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the orders of the Workmen's Compensation Commission.
  • The Court ruled that the award in favor of Conanan had become final and executory.
  • The agency's failure to contest the claim in a timely manner and the untimeliness of its motion for reconsideration were valid ...(Unlock)

Ratio:

  • The Court emphasized the importance of adhering to statutory timelines for contesting claims under the Workmen's Compensation Act.
  • Malan Brothers W...continue reading

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