Luzon Stevedoring Co. v. Commissioner of the Workmen's Compensation Commission
REITERATIONFacts
1. The Antecedents: Teresa Javier Vda. de Gonzales, et al., filed a claim for compensation with the Workmen's Compensation Commission due to the death of Maximino Gonzales, an employee of Luzon Stevedoring Co., Inc. The company moved to dismiss the claim, asserting that the claimants' right of action had already prescribed. Referee Atanacio A. Mardo denied this motion and subsequently ordered the company to pay compensation benefits and burial expenses to the deceased's minor children, while dismissing the claim for the widow and adult children. 2. Procedural History: Following the referee's decision on February 23, 1954, Luzon Stevedoring Co., Inc. filed a motion for reconsideration, reiterating its prescription argument. This motion was denied on April 1, 1954. The company then filed a petition for certiorari with the Supreme Court, which was dismissed because the decision under review was that of the referee, not the Commissioner. Subsequently, the company filed a motion with the Workmen's Compensation Commission requesting the referee to refer the case for review, as the referee had neither amended nor modified his original decision. This motion was denied on September 11, 1954, on the grounds that the decision had become final. 3. The Petition: Luzon Stevedoring Co., Inc. filed the present petition for certiorari seeking to set aside the orders of the respondent Commissioner dated September 11, 1954, and September 22, 1954. The core issue is whether the referee's decision of February 23, 1954, had become final when the company filed its motion to have the case referred to the Commissioner for review. The petitioner argues that the referee's failure to amend or modify his decision necessitated its referral to the Commissioner, and the Commissioner's denial of this referral constituted an abuse of discretion. The petitioner contends that their motion, though termed a motion for reconsideration, effectively sought a review of the referee's decision, which had not yet become final.
Issue(s)
Whether the decision of the referee dated February 23, 1954, had already become final when petitioner filed its motion praying that the case be referred to the Workmen's Compensation Commission for review. Whether the denial of the motion to refer the case to the Commissioner for review constituted an abuse of discretion.
Ruling
The petition is granted. The respondent Commissioner is directed to have the entire record of the case referred to the Commission for review as provided by law.
Ratio Decidendi
On Whether the decision of the referee dated February 23, 1954, had already become final when petitioner filed its motion praying that the case be referred to the Workmen's Compensation Commission for review: The Court held that the decision of the referee had not yet become final. Section 49 of Act No. 3428, as amended by Republic Act No. 772, clearly outlines the procedure for review. It states that any party dissatisfied with a referee's order may petition for review. If the referee does not amend or modify the order, the referee is mandated to refer the entire case to the Commissioner for review. In this case, the referee denied the motion for reconsideration without amending or modifying the original decision. Therefore, the referee's duty was to refer the case to the Commissioner. The petitioner's motion to have the case referred was filed precisely to compel the performance of this statutory duty. The denial of this motion by the respondent Commissioner, on the mistaken belief that the decision had become final, was erroneous. On Whether the denial of the motion to refer the case to the Commissioner for review constituted an abuse of discretion: The Court found that the denial of the motion to refer the case to the Commissioner constituted an abuse of discretion. The referee, after denying the motion for reconsideration without modifying the original decision, failed to perform the mandatory duty of referring the case to the Commissioner for review as required by Section 49 of Act No. 3428, as amended. The petitioner's subsequent motion with the Commission was aimed at rectifying this omission. The Commissioner's denial of this motion, based on the erroneous conclusion that the referee's decision had already become final, was a clear error amounting to grave abuse of discretion. The Court also noted that while the petitioner filed a motion for reconsideration instead of a formal petition for review, this was considered a mere technical error, as the purpose of the motion was effectively to seek a review of the referee's decision.
Main Doctrine
The Court reiterated that under Section 49 of Act No. 3428, as amended by Republic Act No. 772, a party dissatisfied with an order of a referee in a workmen's compensation case has the option to petition for a review. If the referee does not amend or modify the order, the referee is legally bound to refer the entire case to the Commissioner for review. The award of the Commissioner becomes final unless a petition for review is filed within fifteen days after notice of the award. The Court found that the referee's failure to refer the case to the Commissioner after denying a motion for reconsideration, which did not amend or modify the original decision, constituted an abuse of discretion.