Case Digest (G.R. No. L-25665)
Facts:
Victorias Milling Co., Inc. v. Workmen's Compensation Commission and Julio Segovia, G.R. No. L-25665, May 22, 1969, Supreme Court En Banc, Fernando, J., writing for the Court.Claimant Julio Segovia, a former employee of Victorias Milling Co., Inc. (petitioner), filed a notice of injury or sickness and claim for compensation with the WCC Sub-Regional Office in Bacolod on May 20, 1963. The Sub-Regional Office mailed the claim to petitioner by registered mail on June 8, 1963; the registry return receipt showed the claim was received by petitioner on June 17, 1963. Pursuant to WCC practice, the Office requested certain employer and physician reports (WCC Forms Nos. 3–5) under Sec. 37 of the Workmen’s Compensation Act (Act No. 3428, as amended).
Petitioner did not file a timely answer. On December 16, 1963 claimant moved for judgment by default; the WCC granted the motion on December 20, 1963 (order received by petitioner January 17, 1964). An ex parte hearing was held February 4, 1964, after which the hearing officer, Reuben D. Borres of the Bacolod Regional Office, found Segovia’s claim compensable and awarded relief. The Workmen’s Compensation Commission rendered its decision affirming the hearing officer on October 15, 1965.
Petitioner sought review in the Supreme Court by petition to review the Commission’s decision, arguing (inter alia) lack of service of summons and deprivation of due process, that it had not lost its right to controvert, that the claim was filed out of time, and that it was denied opportunity to present its substantial defense. The Supreme Court considered the r...(Subscriber-Only)
Issues:
- Did the Workmen’s Compensation Commission acquire jurisdiction over petitioner and satisfy due process despite the absence of a formal personal service of summons?
- Did petitioner’s failure to file a timely controversion waive or forfeit its defenses, including that the claim was filed out of time?
- Are the Commission’s findings that claimant’s pulmonary tuberculosis was compensable supported by substantial evidence such that the Court should not disturb them?
- Is the award rendered by the Commission final...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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