**Facts:**
Soledad R. Ruivivar was employed as a classroom teacher by the Bureau of Public Schools with an annual salary of PHP 4,844.00. On September 2, 1971, Ruivivar stopped working, claiming she was suffering from toxic goiter and rheumatoid thyroid heart. Subsequently, she filed a claim for disability compensation with the Workmen’s Compensation Unit in Regional Office No. 5, Legaspi City.
The Employer’s Report submitted by the Bureau of Public Schools acknowledged that Ruivivar’s illnesses were acquired through her regular occupation, asserting non-controversion. Furthermore, it confirmed her employment of 18 years at a monthly salary of PHP 367.00 and her sickness and disability.
The Evaluator from the Bureau of Public Schools deemed the claim meritorious and recommended favorable action. Consequently, Regional Office No. 5 granted Ruivivar a disability benefit of PHP 6,000.00, medical expense reimbursement of PHP 3,063.23, and mandated a PHP 61.00 administrative fee.
In February 1976, the Bureau of Public Schools, through the Office of the Solicitor General, sought relief from judgment, arguing they received the decision only on January 27, 1976. The Acting Referee of the Workmen’s Compensation Unit, Regional Office No. 5, denied the petition but elevated the records to the Workmen’s Compensation Commission for review.
**Issues:**
1. Whether the Regional Office No. 5 had jurisdiction over the claim despite not serving notice to the Office of the Solicitor General.
2. Whether the claimant’s illnesses are presumed to be compensable and related to her employment.
**Court’s Decision:**
1. **Jurisdiction:**
The Supreme Court ruled that the Solicitor General’s argument regarding lack of jurisdiction due to the absence of notice was without merit. It relied on precedent from Dinaro vs. Workmen’s Compensation Commission, establishing that non-compliance in serving notice does not invalidate jurisdiction over claims against the Republic if it results in injustice to the claimant.
2. **Compensability:**
The Court underscored that Ruivivar’s illness supervened during her employment, thus triggering the presumption of compensability and causal relation. Furthermore, Ruivivar presented ample evidence showing her illness was caused or aggravated by her employment conditions. Given that the respondent did not provide contradicting evidence, the claimant’s assertion stood. The Workmen’s Compensation Act, designed to favor workers, was interpreted liberally to uphold her claim.
**Doctrine:**
The ruling established that:
– Non-controversion or administrative errors in serving notice to the Solicitor General do not strip the Workmen’s Compensation Commission of jurisdiction over a claimant’s case.
– Illnesses that develop during employment are presumptively related to the job and compensable under the Workmen’s Compensation Act, highlighting the act’s liberal construction in favor of employees.
**Class Notes:**
– **Presumption of Compensability:** Illnesses arising during the course of employment are presumed compensable unless proven otherwise.
– **Liberal Interpretation:** The Workmen’s Compensation Act is to be construed liberally to benefit workers.
– **Jurisdiction:** Failure to serve notice on the Solicitor General does not invalidate jurisdiction if it causes injustice to the employee.
– **Social Legislation:** Work-related disability claims should be resolved in favor of labor to promote social justice.
Key Statutes:
– Section 13 of the Workmen’s Compensation Act
– Article 184 and Article 4 of the New Labor Code of the Philippines
– Article 1702 of the New Civil Code
**Historical Background:**
This case underscores the period’s legal framework focused on worker protection and benefits. The Workmen’s Compensation Act and subsequent laws embodied the social justice principles enshrined in both the 1935 and 1973 Constitutions, reflecting labor-friendly policies to address the vulnerabilities of workers in government service.
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