Title
Pangasi Transportation Co., Inc. vs. Workmen's Compensation Commission
Case
G.R. No. L-16490
Decision Date
Jan 30, 1964
Driver's tuberculosis claim dismissed due to untimely filing; employer's knowledge excused notice but not claim delay. Jurisdiction upheld, compensability moot.
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Case Summary (G.R. No. L-16490)

Motion for Reconsideration

  • The petitioner, Pangasinan Transportation Company, Inc., filed a motion for reconsideration of the Court's decision affirming the Workmen's Compensation Commission's ruling.
  • The motion was based on two grounds:
    1. Claimant Cecilio Gatdula's illness was not caused or aggravated by his employment.
    2. The claim was barred due to failure to notify the employer within the two-month period prescribed by the Workmen's Compensation Act.

Findings on Claimant's Illness

  • The Court found the first ground without merit, affirming the Commission's findings that Gatdula's work as a driver and loader exposed him to tubercular infection.
  • The petitioner's evidence, particularly Dr. Gaerlan's testimony attributing Gatdula's illness to his deceased wife, was deemed speculative and insufficient to counter the statutory presumption of compensability.
  • The Court emphasized that mere possibilities do not negate the presumption established by law.

Timeliness of Claim Submission

  • The Court concluded that the second ground for reconsideration was meritorious, providing a basis for overturning the previous decision.
  • The Workmen's Compensation Commission acknowledged that Gatdula filed his claim on September 2, 1957, which was over two years after he ceased working on January 23, 1955.
  • Despite this, the Commission ruled that the claim was not barred because the employer had actual knowledge of Gatdula's ailment and had ordered him to stop working.

Interpretation of Section 27

  • The Commission's interpretation of Section 27 of the Workmen's Compensation Act was scrutinized, particularly regarding the distinction between notice of injury and claim for compensation.
  • Section 27 allows for sufficient notice of injury but does not extend the same leniency to the claim for compensation, which must be filed within the specified time frame.
  • The Court noted that the statute clearly delineates the requirements for notice and claim, emphasizing that they are separate obligations.

Legislative Intent and Judicial Discretion

  • The Court highlighted that the legislative intent behind the Workmen's Compensation Act is clear, and the time limits set for filing claims are a matter of legislative discretion.
  • The absence of any statutory excuse for late claims, aside from voluntary compensation payments by the employer, was noted.
  • Since no such payments were made by Pangasinan Transportation Co., Inc., the Commission's award was deemed unwarranted.

Jurisdictional Importance of Timely Claims

  • The Court referenced the majority view in the United States, which holds that failure to present a claim within the legal time limit is fatal and jurisdictional.
  • This perspective aligns with previous rulings by the Court, reinforcing t...continue reading

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