Pepito v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Maxima Pepito, a classroom teacher, served from September 23, 1970, to September 30, 1974. After two years, she complained of dizziness, and in 1973, of eye problems, leading to the use of eyeglasses. During the summer vacation of 1973, she sought medical treatment in Bohol and went on sick leave starting June 4, 1973. She gave birth on June 18, 1973. About a month post-delivery, she experienced vomiting and severe headache, was admitted to Saint Jude Hospital with high blood pressure, and despite medication, her condition worsened, leading to complete blindness six months later. She was admitted to Cebu General Hospital on September 29, 1974, where she was diagnosed with a brain tumor. She died the following day, September 30, 1974, of cardio-respiratory arrest due to brain tumor. Procedural History: Petitioner Antonio Pepito filed a claim for disability and death benefits on January 31, 1975. The Department of Labor, Regional Office No. 7, Cebu City, rendered a decision on September 3, 1975, awarding benefits. The Solicitor General filed a petition for relief from judgment and to elevate records on January 7, 1976, 96 days after receiving the referee's decision. The Workmen's Compensation Commission (WCC) reversed the Regional Office's decision on February 11, 1976, absolving the Republic of the Philippines from liability, concluding the illness was not service-connected and was acquired during vacation. The Petition: Petitioner Antonio Pepito sought review of the WCC decision, arguing that the illness was service-connected and that the Solicitor General's petition for relief was filed out of time.
Issue(s)
Whether the deceased teacher's illness (brain tumor) was service-connected. Whether the Solicitor General's petition for relief from judgment was filed within the reglementary period.
Ruling
The Supreme Court reversed and set aside the decision of the respondent Workmen's Compensation Commission. The respondent Bureau of Public Schools was directed to pay death compensation benefits and expenses for medical, hospital, and burial services to claimant Antonio Pepito and his minor daughter Girlie C. Pepito, and to pay administrative fees to the Workmen's Compensation Commission.
Ratio Decidendi
On the issue of service-connection: The Court found the Commission's conclusion that the illnesses were not service-connected to be without basis in fact and law. The deceased teacher exhibited symptoms such as dizziness and deteriorating eyesight after two years of service, which could be indicative of the sickness that caused her death. The Court emphasized that even if the illness was contracted during the long summer vacation, the employee-employer relationship still existed, and the sickness could still be considered service-connected. The Court stated, "We are convinced that the sickness of Maxima C. Pepito that ultimately caused her death is service-connected." The Court also noted that the referee's findings, which were contrary to the Commission's conclusion, were supported by the evidence presented, including the timeline of symptoms and diagnosis. On the timeliness of the petition for relief: The Court held that the Solicitor General's petition for relief from judgment was filed out of time. The referee's decision was received by the Office of the Solicitor General on October 3, 1975, but the petition was filed only on January 7, 1976, after a lapse of 96 days. Under the rules, a referee's decision becomes final fifteen (15) days after receipt unless a timely motion for reconsideration is filed. The Court pointed out that the Commission en banc itself had denied the petition to elevate records for relief from judgment on the ground that it no longer had jurisdiction to review the referee's decision. The Court further stated that while it appreciated the heavy caseload of the Solicitor General's office, pressure of work is not a ground for a petition for relief from judgment, especially in compensation claims which are vital aspects of social justice where time is of the essence for the necessitous man and his heirs.
Main Doctrine
The Workmen's Compensation Commission erred in reversing the award of death and disability benefits, as the deceased teacher's illness was service-connected, and the Solicitor General's petition for relief from judgment was filed out of time, divesting the Commission of jurisdiction.