Robles v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Benito Robles, a public school teacher employed by the respondent Republic of the Philippines (Bureau of Public Schools) for 33 years, applied for optional retirement at age 60 due to illness. He filed a claim for disability compensation benefits approximately three years after his disability, supported by a physician's report stating he suffered from Rheumatic Arthritis, which was contracted and aggravated by his employment due to prolonged standing. The physician noted the condition was ongoing. Procedural History: The Hearing Officer of Regional Office No. 5, San Pablo City, rendered a decision on July 30, 1975, granting petitioner accrued disability compensation benefits and weekly compensation. The respondent employer received the decision on August 14, 1975. The respondent employer filed a motion for extension of time to file a motion for reconsideration, which was granted. However, no motion for reconsideration was filed within the extended period. A certification confirmed the absence of such a filing. Despite this, on December 29, 1975, the respondent employer filed a Petition to Elevate Records for Relief from Judgment with the respondent Commission, admitting the delay and arguing the claim was prescribed and arthritis without complications is not a basis for permanent disability. The Petition: On February 6, 1976, the respondent Workmen's Compensation Commission reversed the Hearing Officer's decision, absolving the employer. Petitioner seeks review of this reversal.
Issue(s)
Whether the Workmen's Compensation Commission had jurisdiction to set aside the decision of the Hearing Officer after it had become final and executory. Whether the respondent employer's reasons constituted valid grounds for relief from judgment despite the lapse of the reglementary period.
Ruling
The judgment of the respondent Commission is reversed and set aside, and the decision of the Acting Referee is reinstated with modifications. The respondent Republic of the Philippines (Bureau of Public Schools) is ordered to pay petitioner Benito Robles P6,000.00 in disability compensation benefits, medical expenses properly receipted for, attorney's fees of P600.00, and to pay the corresponding administrative fee.
Ratio Decidendi
On the issue of jurisdiction: The Court held that the Workmen's Compensation Commission had no jurisdiction over the case after the decision of the Hearing Officer of Regional Office No. 5, San Pablo City, became final and executory. The Court reiterated its ruling in Ramos vs. Republic that a commission's decision must be set aside for being null and void for lack of jurisdiction and authority to set aside an award that was already final and executory. Since no appeal or motion for reconsideration was filed within the fifteen-day reglementary period, the referee's award became final and executory upon the expiration of the deadline. The respondent Commission no longer had jurisdiction to act on the belated Petition to Elevate Records for Relief from Judgment. The referee, in denying the motion, merely had the ministerial duty to issue a writ of execution for the enforcement of the award, not to elevate the record for review. On the issue of grounds for relief: The Court found that the respondent employer's claims of abnormal and extraordinary circumstances, such as the bulk of work assigned to the trial attorney in the Office of the Solicitor General, were not valid excuses for failing to file a motion for reconsideration within the reglementary periods. The records showed that the respondent employer was able to file a motion for extension of time to file a motion for reconsideration. The Court questioned why, instead of filing the motion for reconsideration within the extended period, the counsel filed a petition to elevate the records for relief after the period had long expired. The Court cited Ranada vs. Workmen's Compensation Commission which ruled that mere pressure of work cannot be considered a valid excuse for not filing a motion for reconsideration within the normal reglementary periods. The Court emphasized that the decision of the Hearing Officer had long become final and executory almost four months before the respondent employer filed its petition.
Main Doctrine
A decision of the Hearing Officer becomes final and executory if no appeal or motion for reconsideration is filed within the reglementary period. The Workmen's Compensation Commission loses jurisdiction to act on the case once the decision has become final and executory.