Dimagiba v. Central Bank
REITERATIONFacts
The Antecedents: Petitioner Maria V. Dimagiba was an employee of the Central Bank of the Philippines from September 26, 1955, until her resignation on June 15, 1970, due to an illness diagnosed as "Diabetes Mellitus, Hypercholestemina, GBD." She filed a claim for disability compensation on October 7, 1970. Procedural History: Acting Referee Vivencio E. Escarcha rendered a decision on July 17, 1972, ordering the Central Bank to pay P6,000.00 as disability compensation and P22,299.65 for medical expenses. The Central Bank received this decision on August 7, 1972. The Bank filed a motion for extension to file a petition for review on August 21, 1972, which was granted by the Acting Referee on August 22, 1972, for ten days from August 22, 1972. The Bank filed a second motion for extension on September 7, 1972, which was six days beyond the initial extension period. On October 13, 1972, the Bank filed a Petition for Reconsideration. On October 16, 1972, the Acting Referee issued an order denying the second motion for extension as filed out of time, declaring the decision of July 17, 1972, final and unappealable. The Bank filed a Petition for Review of this order on November 15, 1972, which was denied on March 26, 1974. Subsequently, the Bank filed a Petition for Relief from Order and to Elevate Records on April 3, 1974. The Workmen's Compensation Commission (WCC) rendered a decision on January 30, 1976, affirming the Acting Referee's decision with modifications, awarding P8,154.95 as disability compensation and medical expenses. The Petition: Petitioner seeks review of the WCC's decision, arguing that the Commission abused its authority by reviewing and disturbing the Acting Referee's decision, which had already become final and executory due to the respondent's failure to perfect an appeal within the reglementary period.
Issue(s)
Whether the Workmen's Compensation Commission (WCC) had jurisdiction to review and disturb the decision of the Acting Referee which had already become final and executory. Whether the filing of motions for extension of time to file a petition for review or reconsideration, and the subsequent petition for relief, were filed within the reglementary periods prescribed by law and the rules of the WCC.
Ruling
The Supreme Court reversed and set aside the decision of the respondent Workmen's Compensation Commission dated January 30, 1976, and reinstated the decision of the Acting Referee in favor of the petitioner-claimant. The Central Bank of the Philippines was ordered to pay the claimant P6,000.00 for disability and P22,299.65 for medical expenses, plus attorney's fees and administrative fees.
Ratio Decidendi
On the issue of jurisdiction and finality of the Acting Referee's decision: The Court held that decisions in workmen's compensation cases become final and executory after fifteen (15) days from notice thereof, unless previously appealed or a petition for review has been filed within the same period. The expiration of the reglementary period for reconsideration or review deprives the Commission of appellate jurisdiction to review or set aside the award. In this case, the Acting Referee's decision dated July 17, 1972, became final and executory on August 22, 1972, fifteen days after the respondent Bank received it on August 7, 1972. The subsequent motions and petition for reconsideration were filed beyond the reglementary periods, rendering the decision final and unappealable. The Court emphasized that the Workmen's Compensation Commission had no proper jurisdiction to review the decision once it had become final and executory. On the timeliness of the motions and petition for relief: The Court found no merit in the respondent Bank's contentions regarding the unavailability of transcripts and the claim that the first extension order was not received. The unavailability of transcripts is not a valid ground to excuse the late filing of a motion for reconsideration or petition for review, especially since the Bank was able to file its petition for reconsideration without the transcript. The Court also rejected the argument that the period of finality did not commence to run because the Bank was not notified of the order granting the extension. The Bank had the duty to follow up on its motion and file its petition within the granted period or seek further extension promptly. Furthermore, the petition for relief filed on April 3, 1974, was filed long after the prescriptive periods under Rule 22, Sections 1 and 2 of the WCC Rules had expired, even considering the new rules relied upon by the Bank. Therefore, the Bank could not avail itself of the petition for relief.
Main Doctrine
A decision or award in a workmen's compensation case becomes final and executory after the lapse of the reglementary period to appeal or file a motion for reconsideration, and the Workmen's Compensation Commission loses jurisdiction to review or set aside such award once it has become final and executory.