Jordan v. J. de Dios Enterprises, Inc.
REITERATIONFacts
1. The Antecedents: Bienvenido Jordan, employed by J. de Dios Enterprises, Inc., sustained serious physical injuries on December 31, 1963, during the course of his employment. He subsequently filed a claim for compensation and benefits under Act 3428, as amended, due to these injuries. 2. Procedural History: Jordan's initial claim resulted in an award from Regional Office No. 4. The employer, J. de Dios Enterprises, Inc., failed to controvert the claim timely, leading to the award. However, the employer's subsequent petition to set aside the award was denied. The case was then elevated to the Workmen's Compensation Commission (WCC), which issued conflicting orders regarding the remanding of the case for further hearings. A tie vote among the commissioners led to the affirmation of an earlier order, and subsequent proceedings were conducted based on that affirmed order, culminating in a decision by Referee Pelaez. This decision was later set aside by Chairman Baens del Rosario, who rendered her own decision. The WCC en banc then resolved to set aside the Chairman's decision and remand the case for a full hearing, prompting the current appeal. 3. The Petition: The heirs of Bienvenido Jordan, substituted for the deceased claimant, seek certiorari to review the WCC en banc's resolution of February 29, 1968. They argue that the controlling order for the case's proceedings should be the WCC's order of September 3, 1964, which was affirmed due to a tie vote, and not the subsequent order of December 3, 1964, which the WCC en banc relied upon for its resolution. The petitioners contend that the decision of Chairman Baens del Rosario, which aligned with the September 3, 1964 order, should be reinstated.
Issue(s)
Whether the order of September 3, 1964, or the order of December 3, 1964, issued by Associate Commissioner Perez, was the controlling order in the premises. Whether the decision of Chairman Baens del Rosario dated July 10, 1967, was rendered in accordance with law and the proceedings had. Whether the resolution of the Commission en banc dated February 29, 1968, remanding the case for a full hearing on the merits, should be affirmed or set aside.
Ruling
The Supreme Court declared the order of December 3, 1964, issued by Associate Commissioner Cesareo Perez, as having no legal effect. It affirmed the validity and controlling nature of his own order of September 3, 1964. Consequently, the Court reversed and set aside the resolution of the Commission en banc issued on February 29, 1968, and affirmed the decision rendered by Chairman Baens del Rosario on July 10, 1967.
Ratio Decidendi
On Issue 1: The Supreme Court held that the order penned by Associate Commissioner Perez on September 3, 1964, was the controlling order. This order was issued in his capacity as a reviewing commissioner and was subject to appeal to the Commission en banc via a motion for reconsideration. When the employer filed a motion for reconsideration, it was appealed to the Commission en banc. According to Section 4, Rule 17 of the Commission's Rules, two affirmative or negative votes are needed to decide a case, and in case of a tie, the original or appealed decision or order shall be deemed affirmed. In this instance, the Perez order of September 3, 1964, resulted in a tie vote upon appeal, with the Chairman voting for affirmance and Commissioner Perez voting for modification. As the tie was not broken by a second vote, the appealed order of September 3, 1964, was deemed affirmed by operation of law. Furthermore, an order issued on July 14, 1966, by the Chairman explicitly declared the September 3, 1964 order as affirmed, and no appeal was taken from this order. The subsequent order of December 3, 1964, which modified the September 3, 1964 order, was thus rendered without legal effect. On Issue 2: The Supreme Court believed that even if there was an error in setting aside Referee Pelaez's decision, it was not fatal nor did it cause substantial prejudice to the Company. The Court considered two possibilities: first, that the referee was authorized to receive evidence and render judgment, in which case Pelaez's decision was legal, and Chairman Baens del Rosario's decision was a correct appeal ruling that slightly modified the relief granted. Second, if Pelaez's decision exceeded his authority as limited by the September 3, 1964 order, then Chairman Baens del Rosario acted correctly in setting it aside and rendering judgment herself based on the evidence of record. In either scenario, the Chairman's decision of July 10, 1967, was deemed to be in accordance with law and the conditions of the September 3, 1964 order. On Issue 3: The Supreme Court reversed and set aside the resolution of the Commission en banc dated February 29, 1968. This resolution had set aside Chairman Baens del Rosario's decision of July 10, 1967, and ordered a remand for a full hearing based on Associate Commissioner Perez's order of December 3, 1964. Given that the Court found the September 3, 1964 order to be controlling and the December 3, 1964 order to be without legal effect, the en banc resolution that relied on the latter was necessarily erroneous. Therefore, the decision of Chairman Baens del Rosario, which was consistent with the controlling September 3, 1964 order, was affirmed.
Main Doctrine
The Supreme Court held that when a motion for reconsideration before the Workmen's Compensation Commission results in a tie vote, the original or appealed decision or order is deemed affirmed, as per Section 4, Rule 17 of the Commission's Rules. This principle dictates that a tie vote does not nullify the prior ruling but effectively upholds it. The Court also emphasized that the failure of an employer to controvert a claim within the statutory period renders the compensability of the injury or illness undisputed, thereby limiting subsequent proceedings to the determination of the extent of benefits.