Case Digest (G.R. No. L-30427)
Facts:
Rosendo M. Manlapat v. Workmen's Compensation Commission and Reynaldo Padelara, G.R. No. L-30427, June 28, 1973, the Supreme Court En Banc, Fernando, J., writing for the Court.Petitioner Rosendo M. Manlapat was the employer of claimant Reynaldo Padelara, who worked as a tailor in the R. M. Manlapat Tailoring Shop in Manila. According to the findings of the respondent Workmen's Compensation Commission (WCC), on April 26, 1962 Padelara and two fellow tailors left the shop at about 5:00 p.m. to take a snack at a nearby restaurant. While taking their snack, unidentified persons assaulted Padelara; he broke away, ran toward the tailoring shop, was overtaken, beaten, left prostrate and bleeding, and was brought by the shop driver to the North General Hospital. Medical records show multiple head and bodily injuries, hospitalization from April 26 to May 24, 1962, and a craniotomy performed on May 12, 1962.
Before the WCC, the employment relationship and compensable nature of the injury were found in favor of Padelara. Petitioner initially objected on several grounds: denial of an employer-employee relation, that the injury did not arise out of or in the course of employment, that the claim was filed beyond the two-month period required by Section 24 of the Workmen's Compensation Act, and that the claimant's negligence barred recovery. The chief referee rendered a decision on September 30, 1965; petitioner filed a motion for reconsideration (November 19, 1965) largely repeating the same grounds. The WCC issued the decision now under review on May 9, 1968, adverse to petitioner.
After the Commission's decision, petitioner again sought reconsideration (pleading filed June 5, 1968) and—only at that late stage—raised a constitutional due process objection in one sentence, invoking recent Supreme Court decisions decided after the referee's hearing. Petitioner then brought this petition to the Supreme Court seekin...(Pro-only)
Issues:
- Did the WCC hearing and award violate petitioner's constitutional right to due process because the decision allegedly lacked evidentiary support and relied on hearsay?
- Did the injury to the claimant arise out of and in the course of employment so as to be compensable?
- Was the claim barred by failure to comply with the two-month filing requirement of Section 24 of ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)