Page's Department Store v. Velardi

In Page's Department Store v. Velardi, 464 Pa. 276, 346 A.2d 556 (1975), the court held that an amendment to what was formerly section 423 of the Act, deleted by section 18 of the Act of June 24, 1996, P.L. 350, 77 P.S. 854, which altered the WCAB's scope of review by precluding the WCAB from issuing findings of fact without first taking additional evidence, was procedural in nature because the change had no bearing on a claimant's right to relief upon a given set of facts. The court contrasted the modification of the WCAB's scope of review with the 1972 amendments to section 301(a) of the Act, 77 P.S. 431, which eliminated the requirement of proof of an "accident" and, thus, altered the facts that a claimant must prove in order to establish entitlement to benefits.