Ranada v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioners, Mary J. Ranada and her children, filed a claim for death benefits under the Workmen's Compensation Act following the death of Judge Santiago Ranada Sr. due to stress gastric bleeding. The deceased judge had undergone three surgeries for gastric bleeding and his attending physician stated his illness was work-connected and aggravated by his employment, noting the nature of his work involved significant stress. Procedural History: The Acting Labor Referee awarded petitioners P5,400.00 as death compensation and P13,367.12 as reimbursement for medical expenses, totaling P18,767.12, plus attorney's fees and a decision fee. The respondent Republic (Supreme Court), through the Office of the Solicitor General (OSG), received the decision on November 17, 1975. On December 11, 1975, 24 days after receipt, the OSG filed a "Petition To Elevate Records." Petitioners objected, arguing the decision had become final and executory. The Petition: Despite the objection, the records were forwarded to the respondent Commission, which motu proprio modified the decision, reducing the medical expense reimbursement to P4,545.50. Petitioners filed the present petition for review, questioning the Commission's jurisdiction to act on an appeal filed beyond the statutory period.
Issue(s)
Whether or not the Workmen's Compensation Commission (WCC) acted within its jurisdiction in taking cognizance of and modifying the decision of the Acting Labor Referee when the appeal was filed beyond the 15-day period allowed by law.
Ruling
The petition is granted. The decision of the respondent Commission is reversed and set aside, and the decision of the Acting Labor Referee is reinstated.
Ratio Decidendi
On Issue 1: The Supreme Court held that the Workmen's Compensation Commission (WCC) lost jurisdiction to review the case because the Acting Labor Referee's decision had already become final and executory. Pursuant to Section 49 of the Workmen's Compensation Act (WCA), a party dissatisfied with a referee's award must file a petition for review within fifteen days from notice of the entry of the order. In this case, the Office of the Solicitor General (OSG) received the decision on November 17, 1975, and its failure to act until December 11, 1975, meant the 15-day period had lapsed. Applying Ramos v. Republic (G.R. No. L-41949), the Court emphasized that the expiration of this reglementary period deprives the administrative body of appellate jurisdiction to review or set aside the award. The Court specifically rejected the OSG's defense of 'pressure of work,' ruling that it does not constitute 'excusable negligence' sufficient to warrant relief from judgment. Furthermore, the petition for relief was fatally defective because the accompanying affidavit of merit contained mere conclusions and opinions rather than facts showing a substantial defense against the medical expense claims.
Main Doctrine
The Workmen's Compensation Commission loses jurisdiction to review a decision of an Acting Labor Referee if the petition for review is filed beyond the reglementary period, and mere pressure of work does not constitute excusable negligence to warrant relief from judgment.