Carreon v. Workmen's Compensation Commission
REITERATIONFacts
1. The Antecedents: These consolidated cases involve claims for disability compensation benefits filed by Pedro Carreon and Bienvenido Regala against the Republic of the Philippines, represented by the Bureau of Posts and the Bureau of Agricultural Extension, respectively. Carreon claimed disability due to arteriosclerotic heart disease aggravated by his employment as a mail carrier, while Regala claimed disability due to pulmonary tuberculosis and a bleeding ulcer incurred as a laborer involving strenuous work and carrying heavy construction materials. 2. Procedural History: In both cases, referees initially rendered decisions granting disability compensation and medical expense reimbursement to the respective petitioners. Copies of these decisions were received by the respondent Republic through the Office of the Solicitor General. However, the respondent Republic filed motions to set aside these decisions well beyond the fifteen-day reglementary period for appeal. The referees correctly denied these motions as the decisions had become final and executory. Despite this, the Workmen's Compensation Commission ordered the elevation of the records and subsequently issued decisions dismissing the claims for lack of merit. 3. The Petition: The petitioners seek review of the Workmen's Compensation Commission's decisions, arguing that the Commission lacked jurisdiction and authority to set aside awards that had already become final and executory due to the respondent's failure to file timely appeals. The petitions are grounded on the fundamental principle that judgments and awards, once final, are immutable and beyond alteration, with no timely petitions for relief having been filed by the respondent in either case.
Issue(s)
Whether the Workmen's Compensation Commission has the jurisdiction and authority to set aside decisions of its referees that have already become final and executory due to the failure of the respondent to appeal within the reglementary period. Whether the failure to file an appeal within the reglementary period renders a decision final and executory, depriving the appellate body of jurisdiction.
Ruling
The Supreme Court annulled the decisions of the respondent Commission and reinstated the referees' awards of disability compensation in favor of the petitioners-claimants, with a modification increasing the attorney's fees.
Ratio Decidendi
On the issue of the Commission's jurisdiction to set aside final and executory awards: The Supreme Court held that the respondent Commission no longer had the authority and jurisdiction to set aside the referees' decisions that had already become final and executory. This was due to the failure of the respondent Republic to take an appeal within the reglementary period prescribed by law. The fundamental ground for this ruling is the basic rule of finality of judgments, which is applicable to all, regardless of whether the employer is public or private. This rule is grounded on public policy and sound practice, ensuring that judgments and awards become final at a definite date fixed by law. The Court emphasized that the lapse of the appeal period deprives the appellate courts of jurisdiction to alter the final judgment. On the mandatory nature of the reglementary period for appeal: The Court reaffirmed the principle that the perfection of an appeal within the statutory or reglementary period is mandatory and jurisdictional. Failure to perfect an appeal within this period renders the questioned decision final and executory. Consequently, the appellate court is deprived of jurisdiction to entertain the appeal. The lapse of the appeal period extinguishes the jurisdiction of the courts to alter the final judgment. An exception to this rule exists only when there is a timely petition for relief from judgment, which was not filed or granted in the cases at bar.
Main Doctrine
The Workmen's Compensation Commission lacks jurisdiction to set aside an award that has become final and executory due to failure to appeal within the reglementary period.