G.R. No. L-43628 June 22, 1978
Estrella B. Ferrer, petitioner, vs. The Workmen’s Compensation Commission and Republic of the Philippines (Bureau of Public Schools), respondents.

FACTS

Estrella B. Ferrer, a classroom teacher in the public school system from September 22, 1939, until her optional retirement on May 24, 1973, filed a claim for disability benefits under the Workmen’s Compensation Act. She alleged that her illnesses—coronary insufficiency, PTB, and chronic bilateral mastoiditis resulting in total deafness—were suffered in the course of and aggravated by her employment. The respondent employer, the Republic through the Bureau of Public Schools, did not controvert this claim.
The Acting Referee awarded Ferrer compensation, including reimbursement for medical expenses and the maximum disability benefit for her 90% non-scheduled disability. However, the Workmen’s Compensation Commission reversed this award on appeal. The Commission held that Ferrer failed to prove a causal connection between her ailments and the nature of her employment, thereby absolving the respondent from liability.

ISSUE

Whether the Workmen’s Compensation Commission erred in denying Estrella B. Ferrer’s claim for disability benefits.

RULING

Yes, the Supreme Court reversed the Commission’s decision and reinstated the award. The legal logic is anchored on two pivotal principles under the Workmen’s Compensation Act. First, Section 44 establishes a rebuttable presumption that an illness which supervenes during employment either arose out of or was aggravated by said employment. This presumption shifts the burden of proof to the employer to disprove compensability. In this case, the respondent employer failed entirely to discharge this burden.
Second, and decisively, the respondent’s failure to controvert Ferrer’s claim within the statutory period mandated by Section 45 of the Act constituted a waiver of its right to challenge the claim on non-jurisdictional grounds, including the defense of non-compensability. This waiver is absolute and operates by law. Furthermore, Ferrer presented competent evidence through a Physician’s Report (Exhibit “B”) which explicitly stated that her coronary insufficiency was directly caused by her employment, noting that the emotional strain inherent in teaching duties could be a causative factor. A Compensation Rating Medical Officer also certified her 90% disability. Given the statutory presumption, the uncontroverted claim, and the supporting medical evidence, the Commission’s conclusion was legally untenable. The employer’s liability was thus conclusively established.