Chef Products, Inc. v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Juan Torella and Pedro Torella, employees of petitioner Chef Products, Inc., filed separate claims for compensation under the Workmen's Compensation Act, as amended. They alleged that they contracted tuberculosis, or that their condition was aggravated, in the course of and by their employment with the petitioner. Procedural History: The Workmen's Compensation Commission initially awarded compensation to both Juan and Pedro Torella on September 5, 1968. Petitioner Chef Products, Inc. filed motions for reconsideration on September 25, 1968, admitting liability under Section 14 but contesting compensation under Section 18 and the non-application of Section 22 for an 8% discount on lump sum payments. Associate Commissioner Herminia Castelo-Sotto denied these motions on November 7, 1968, citing that they were filed out of time. Petitioner then filed a motion for reconsideration with the Commission en banc on November 11, 1968, challenging the denial. The Commission en banc denied this motion on February 26, 1969, again citing the untimeliness of the initial reconsideration motion. Petitioner received notice of this denial on March 5, 1969, and subsequently filed a notice of appeal with the respondent Commission for review by the Supreme Court. The Petition: Petitioner Chef Products, Inc. seeks review of the Workmen's Compensation Commission's decision, arguing that the award of non-scheduled disability benefits under Section 18 was erroneous and illegal, that the Commission erred in holding their motion for reconsideration filed on September 25, 1968, to be out of time, and that the Commission erred in not allowing an 8% discount for lump sum payment under Section 22. The core issue before the Supreme Court is whether the petition for review is in order, considering the Commission's ruling that the appeal from Associate Commissioner Castelo-Sotto's order of September 5, 1968, was filed beyond the ten-day reglementary period.
Issue(s)
Whether the petition for review is in order, considering the WCC's ruling that the appeal from the order of Associate Commissioner Castelo-Sotto was filed out of time. Whether the award of non-scheduled disability benefit under Section 18 of the Workmen's Compensation Act was erroneous and illegal. Whether the motion for reconsideration filed by petitioner was filed out of time. Whether the WCC erred in not allowing a discount for lump sum payment under Section 22 of the Workmen's Compensation Act.
Ruling
The Supreme Court affirmed the orders of the respondent Workmen's Compensation Commission denying the motions for reconsideration and denied the petition for review. The Court sustained the WCC's ruling that the appeal from the order of Associate Commissioner Castelo-Sotto was filed out of time.
Ratio Decidendi
On the timeliness of the appeal: The Supreme Court reiterated that the period for filing a motion for reconsideration to the Commission en banc from a decision or order of an individual Commissioner is ten (10) days from official receipt of a copy thereof. The Court found that the petitioner filed its motion for reconsideration beyond this ten-day period, rendering the order of Associate Commissioner Castelo-Sotto final. The Court clarified that the fifteen-day period invoked by the petitioner applies only to appeals from an award made by a Referee to the Commission, not from an individual Commissioner's order to the Commission en banc. Therefore, the petition for review was filed out of time. On the award of non-scheduled disability benefit: The Court deemed it unnecessary to discuss the alleged error in awarding non-scheduled disability benefits because the petition was dismissed on procedural grounds (being filed out of time). The finality of the WCC's order due to the late filing of the motion for reconsideration precluded further substantive review of the award. On the motion for reconsideration being filed out of time: As stated above, the Court found that the motion for reconsideration filed by the petitioner on September 25, 1968, was indeed filed out of time. The order of Associate Commissioner Castelo-Sotto was received on September 19, 1968, and the motion for reconsideration was filed on September 25, 1968, which falls within the 10-day reglementary period. However, the Court's discussion on the denial of the motion for reconsideration by Associate Commissioner Castelo-Sotto on November 7, 1968, states that the motion was filed on September 25, 1968, despite receipt of the order on September 19, 1968. The Court's final ruling, however, emphasizes that the appeal from the order of September 5, 1968, to the Commission en banc was filed beyond the ten (10) days from receipt of notice thereof. This implies that the initial motion for reconsideration to Associate Commissioner Castelo-Sotto was also considered late by the Commission en banc in its resolution of February 26, 1969, which upheld the order of November 7, 1968. The Court's ultimate conclusion is that the appeal to the Commission en banc was late. On the discount for lump sum payment: Similar to the issue of non-scheduled disability benefits, the Court did not delve into the merits of the discount for lump sum payment. The procedural defect of late filing rendered the WCC's order final, and thus, the substantive issues raised by the petitioner, including the discount, were not passed upon.
Main Doctrine
The ten (10) day period for filing a motion for reconsideration to the Commission en banc from an order of an individual Commissioner is strictly enforced. Appeals filed beyond this period are considered late and the order becomes final.