Roma v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Claimant Victoria M. Roma, a classroom teacher, filed a claim for disability benefits due to loss of voice and difficulty in talking, alleging her ailment commenced in 1966 and worsened in November 1973. Her physician diagnosed her with pulmonary tuberculosis and chronic laryngitis, probable consequences of her employment, rendering her incapacitated for teaching. She retired on June 2, 1975, at age 44, after 26 years of service. Procedural History: An acting referee rendered a decision awarding disability compensation and weekly compensation to the claimant. The respondent employer, Bureau of Public Schools, received a copy of this decision on October 27, 1975. No motion for reconsideration was filed. On November 28, 1975, the employer filed a "Petition to elevate records for relief from judgment," which was two days beyond the 30-day period prescribed by the Workmen's Compensation Commission Rules for filing such a petition. By this time, the referee's decision had become final and executory. The Petition: The claimant-petitioner sought to set aside the decision of the Workmen's Compensation Commission which reversed the referee's award, arguing that the Commission lost jurisdiction because the referee's decision had already become final and executory.
Issue(s)
Whether the Workmen's Compensation Commission had jurisdiction to render a decision reversing the referee's award when the employer failed to file a petition for relief from judgment within the reglementary period. Whether the claimant's illness (pulmonary tuberculosis and chronic laryngitis leading to loss of voice) is compensable under the Workmen's Compensation Act. Whether the employer controverted the claimant's claim for compensation as required by law.
Ruling
The Court set aside the decision of the respondent Commission and reinstated the award of the acting referee, declaring it final and enforceable.
Ratio Decidendi
On the issue of jurisdiction and the timeliness of the petition for relief: The Court held that the Workmen's Compensation Commission had lost jurisdiction to render a decision reversing the referee's award because the employer failed to file its petition for relief from judgment within the reglementary period. The referee's decision became final and executory on November 27, 1975, after the 30-day period for filing a motion for reconsideration expired. The employer's petition for relief, filed on November 28, 1975, was two days late. Citing Tomas U. Soliven vs. Workmen's Compensation Commission, the Court emphasized that the period for filing a petition for relief is "absolutely fixed, inextendible, never interrupted and cannot be subjected to any condition or contingency." Failure to avail of this last chance within the grace period is fatal. The Court further clarified that the two periods for seeking relief – 30 days after notice and three months after judgment – must concur, and the employer's petition was filed beyond 30 days from notice, making it fatally defective. The Commission's decision was therefore null and void for want of jurisdiction. On the compensability of the claimant's illness: The Court found the claimant's illness to be compensable. The claimant, a classroom teacher, suffered from pulmonary tuberculosis and chronic laryngitis, resulting in the loss of her voice and inability to teach. The physician's report indicated that the laryngitis was "Koch's" in origin, meaning it was attributable to tuberculous bacilli, thus establishing an intimate connection between her pulmonary tuberculosis and her loss of voice. The Court reiterated its consistent ruling that a disability caused by a disease or injury incurred or aggravated in the course of employment is compensable, creating a presumption of compensability that must be rebutted by substantial evidence. The claimant's early retirement at age 44 due to her weakened bodily condition, contracted in the course of employment, further supported her claim for compensation for inability to work. The Court also noted that the claimant's optional retirement at an early age, due to physical incapacity to render efficient service, placed the fact of her disability beyond doubt. On the employer's failure to controvert the claim: The Court found that the respondent employer failed to controvert the petitioner's claim for compensation as required by Section 45 of the Workmen's Compensation Act, as amended. The Court has consistently ruled that such failure constitutes a renunciation of all non-jurisdictional defenses and is an ultimate admission of compensability. Therefore, the employer's defenses, if any, were deemed waived.
Main Doctrine
A decision of the Workmen's Compensation Commission reversing a referee's decision is null and void if rendered after the referee's decision had become final and executory due to the employer's failure to appeal or file a petition for relief within the reglementary period.