Title
Manlapat vs. Workmen's Compensation Commission
Case
G.R. No. L-30427
Decision Date
Jun 28, 1973
Employee injured during work-recognized coffee break; claim upheld despite late filing, as injuries deemed work-related and employer failed to controvert.
due process
injury
award

Case Summary (G.R. No. L-30427)

Factual Background

The Workmen’s Compensation Commission found that Padelara, while employed with the R. M. Manlapat Tailoring Shop in Manila, left the shop at around 5:00 p.m. with two other tailors, Gregorio Corpus and Dante Badel, to take their snack at a restaurant about a block away. While he was actually taking his snack, Padelara was suddenly assaulted by several unidentified persons.

Padelara managed to break off and ran toward the tailoring shop. He was overtaken by the pursuers, who inflicted further injuries and left him prostrate and bleeding. He was brought, in a semi-conscious condition, to the North General Hospital and admitted to its emergency ward, where his injuries were diagnosed as: a depressed fracture (parietal, left); a stabbed wound; a lacerated T-shaped wound (supraciliary, left); a hematoma with a lacerated wound; diffused neuronal injury (moderate); and a contusion (posterior ear, left). He was confined from April 26, 1962 to May 24, 1962, and during confinement a craniotomy was performed on May 12, 1962.

Commission Award and the Employer’s Initial Grounds

Based on those findings, and on the employment relationship shown, the Commission rejected the employer’s objections. The Supreme Court noted that the supposed late filing and the supposed non-compensability of the injury did not detract from the Commission’s conclusions. The Court also highlighted that the injury was inflicted during the coffee-break period recognized by the employer, which tended to negate the employer’s contention that the injury did not arise out of and in the course of employment.

The Supreme Court therefore treated the decisive controversy as whether the employer had shown a due process violation in the proceedings before the Commission. The employer also raised, in addition, that the injury did not arise out of the course of employment and that Padelara failed to comply with Section 24 by filing the claim beyond the statutory period.

Issues Raised on Petition for Review

The employer’s petition for review assigned errors that, as framed by the Court’s discussion, could be organized into three main questions: first, whether the Commission’s hearing and decision were vitiated by a failure to observe due process, particularly the requirement that the decision find support in the evidence presented at the hearing; second, whether the injuries were non-compensable because they did not arise out of and in the course of employment; and third, whether the claim was barred for late filing under Section 24.

Employer’s Due Process Objection and the Court’s Assessment

The Court emphasized that due process in administrative adjudication includes cardinal primary rights, one of which is that the administrative decision must find support in the evidence presented at the hearing. The Court relied on the lineage of doctrine beginning with Ang Tibay v. Court of Industrial Relations and reiterated through later cases, including Ozaeta v. Oil Industry Commission, where the Court cited Ang Tibay with approval and referenced numerous decisions adhering to that pronouncement.

In examining the record, the Court concluded that the employer’s due process claim lacked intrinsic merit and also lacked adequate evidentiary support. The Court observed that, in the employer’s memorandum to the regional office dated January 14, 1964, the employer’s objections were directed mainly to: the non-existence of an employer-employee contract; the injury not arising in the course of employment; the alleged bar for filing beyond the two-month statutory period; and the claimant’s alleged notorious negligence. The employer did not meaningfully raise due process at that stage.

When the chief referee rendered the decision on September 30, 1965, the employer filed a thirty-six page motion for reconsideration on November 19, 1965. The Court noted that only a tangential portion—two pages—contained any due process reference. Even then, the employer’s later pleadings and the limited space devoted to the issue led the Court to infer that the due process theory was not the product of the employer’s original litigation posture.

The Court further traced the employer’s conduct in later stages. It noted that the employer’s June 5, 1968 pleading sought reconsideration only after earlier proceedings, and only then did a one-sentence due process reference appear, acknowledging that certain rulings of the Supreme Court had come to the employer’s attention and could bolster the case. The Court found that the employer’s conduct and the scanty treatment of due process undermined the claim that the alleged defect was decisive. The Court also pointed out that even in the employer’s twenty-three page brief, less than two pages were devoted to the due process aspect.

Reliance on Post-Hearing Decisions and Lack of Persuasive Force

The Court examined the employer’s use of later Supreme Court rulings to construct the due process argument. The Court recorded that the employer invoked two decisions promulgated after the hearing before the chief referee: Aboitiz Shipping Corporation v. Pepito (December 17, 1966) and Magalona v. Workmen’s Compensation Commission (December 11, 1967).

As to Aboitiz Shipping Corporation v. Pepito, the Court quoted the holding that an award made before the petitioner was given an opportunity to be heard on the debatable fact and circumstances of death had no legal basis and was nullified for violating a constitutional prescription. The Court contrasted that scenario with the present case, stating that the facts about the injury were not shown to be debatable at the hearing before the chief referee, and that the employer had an opportunity to raise the issues now being pressed.

As to Magalona v. Workmen’s Compensation Commission, the Court emphasized the principle that no evidence could be taken into account where the adverse party had not been given the opportunity to object to its admissibility. The Court found that, from the facts narrated, there was again nothing indicating that the circumstances were debatable or that the employer had been denied the opportunity to object at the proper stage.

The Court stressed that the employer could not reasonably rely on decisions rendered three years and four years after the hearing to weaken the standing of the Commission’s award. The Court therefore rejected the due process theory for being afterthought-like, weak in premise, and unsupported by the record.

Treatment of Alleged Hearsay and Section 49 of the Workmen’s Compensation Act

The employer also attacked the evidentiary basis of the award by portraying certain materials as hearsay and claiming that any award based on such evidence would be “void and violative of the constitutional prescription of due process.” The Court rejected that argument by referring to National Development Company v. Workmen’s Compensation Commission, where the Court explained why exhibits that might be hearsay under common-law rules were nonetheless admissible in compensation proceedings under Section 49.

The Court reiterated that Section 49 was designed for a more simple and summary method of proof in recognition of the policy of workers’ compensation legislation. It further quoted the statutory structure: the Commissioner may receive and use, as evidence and proof of disputed facts, in addition to sworn testimony, matters that include reports of attending examining physicians, reports of investigators appointed by the Commissioner, reports of the employer (including records and copies of time sheets and book accounts), and hospital records in relation to the case. The Court concluded that,

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