G.R. No. L-19019 - Malan Brothers Watchman Agency vs. Coan

A claim for compensation filed by an employee is deemed admitted if not reasonably controverted within the statutory timeframe.
An award in favor of the employee can be made based on the claim and accompanying evidence without requiring a formal hearing.
This principle is supported by precedent, specifically the case of Bachrach Motor Co. Inc. vs. The Workmen's Compensation Commission.

A notice of an award issued by the Regional Administrator of the Department of Labor is considered complete five days after the employer receives the first registry notice.
This completion of notice is crucial for determining the timeline for any subsequent actions by the employer.

Respondent Magdaleno Conanan, employed by Malan Brothers Watchman Agency, sustained an injury while on duty as a security guard.
The injury occurred on November 6, 1959, due to an accidental discharge of his service pistol.
Conanan filed a compensation claim on January 6, 1960, which was sent to the employer, but the necessary forms were returned unclaimed.
A second attempt to notify the employer was made on March 29, 1960, which was acknowledged by the employer's manager on April 4, 1960.
The employer submitted a controversion of the claim on October 3, 1960, but this was deemed late, as it was filed after the statutory period.

The Regional Administrator awarded Conanan P3,371.46 on October 12, 1960, due to the employer's failure to timely contest the claim.
The employer refused to claim the award despite receiving multiple registry notices.
A follow-up letter was sent on February 1, 1961, requiring payment of the award, but the employer only moved for reconsideration on February 3, 1961.

The principal issue was whether the award had become final and executory when the employer sought reconsideration.
The Regional Administrator's determination that the employer failed to controvert the claim was upheld, as the controversion was filed late.
The employer's motion for reconsideration was also deemed untimely, as it was filed more than sixty days after the notice of the award was complete.

The employer's argument that the award was void due to the lack of a formal hearing was rejected.
Since Conanan's clai...continue reading