Ramos v. Republic
REITERATIONFacts
The Antecedents: Petitioner Jacinta J. Ramos filed a claim for workmen's compensation benefits against the Bureau of Census and Statistics (now respondent Republic). On July 25, 1974, the Acting Chief Referee issued an Award declaring the claim uncontroverted and ordering the Bureau to pay petitioner P6,000.00 as disability compensation for neuro-circulatory asthenia with slight heart enlargement and hepatitis, plus P61.00 for administrative fees. Procedural History: The Office of the Solicitor General, representing the Bureau, received a copy of the Award on October 31, 1974. The award became final and executory on November 15, 1974, as no motion for reconsideration or review was filed within the fifteen-day reglementary period. Instead, on November 14, 1974, the Bureau's counsel filed a motion for clarification regarding the total liability, which was issued on November 29, 1974, clarifying the P6,000.00 limit and directing satisfaction of the award. On December 6, 1974, the Bureau's counsel advised the Bureau to pay the award. However, on January 23, 1975, long after the reglementary period had lapsed, the Bureau filed a motion to set aside the award, claiming a timely controversion had been made on June 28, 1974, and invoking the right to a hearing. Petitioner opposed this, asserting the Commission's loss of jurisdiction. The Hearing Officer found the motion not meritorious but elevated the record for review. On October 24, 1975, the Commission, instead of ordering enforcement, reviewed the case and reversed the referee's decision, absolving the respondent from liability. The Petition: Petitioner filed the instant petition, treated as a special civil action, seeking to annul the Commission's decision for lack of jurisdiction.
Issue(s)
Whether the Workmen's Compensation Commission had jurisdiction to set aside an award that had become final and executory. Whether the respondent Bureau of Census and Statistics waived its right to controvert the claim by failing to file a timely controversion and by its subsequent actions.
Ruling
The Supreme Court set aside the decision of the respondent Workmen's Compensation Commission dated October 24, 1975, declaring it null and void for lack of jurisdiction. The Court ordered the enforcement of the referee's award dated July 25, 1974.
Ratio Decidendi
On the issue of the Commission's jurisdiction to set aside a final and executory award: The Court held that once an award of the Workmen's Compensation Commission becomes final and executory, the Commission loses jurisdiction over the case, except for the ministerial duty of enforcing the award. In this case, the referee's award dated July 25, 1974, became final and executory on November 15, 1974, as no motion for reconsideration or review was filed within the fifteen-day reglementary period. The subsequent motion to set aside the award filed on January 23, 1975, was therefore filed beyond the period prescribed by law, and the Commission had no authority to act upon it. The Court emphasized that the rule of finality is grounded on public policy and sound practice, ensuring that judgments and awards become final at a definite date fixed by law. This rule applies indiscriminately to all parties, whether public or private employers. On the issue of waiver of the right to controvert: Even assuming, for the sake of argument, that the respondent's second controversion filed on June 28, 1974, was timely, the Court found that the respondent, duly assisted by government counsel, waived any right to a hearing. After receiving the award on October 31, 1974, they did not assert their grounds for challenging the claim's compensability. Instead, their counsel merely filed a motion for clarification, and upon obtaining it, advised that payment was in order. This action reaffirmed the compensability of the claim, which should have been deemed admitted due to the failure to seasonably controvert it. Therefore, the respondent's contention that the award was void and could be set aside at any time due to being deprived of a hearing was deemed untenable. The Court reiterated that the expiration of the reglementary period for reconsideration or review deprives the Commission of appellate jurisdiction, and appeals filed out of time are consistently rejected.
Main Doctrine
A decision, order, or award of the Workmen's Compensation Commission that has become final and executory can no longer be set aside or modified by the Commission, as it loses jurisdiction over the case except to enforce the award.