Soliven v. Workmen's Compensation Commission
REITERATIONFacts
1. The Antecedents: These consolidated cases involve claims for disability compensation and benefits filed by two teachers, Tomas U. Soliven and Eulogia Malijan, against the Republic of the Philippines (Bureau of Public Schools). Soliven claimed disability due to bronchial asthma and neuritis, forcing his retirement in 1966. Malijan claimed disability for myxedema goiter and hemorrhoids during her teaching service. 2. Procedural History: In both cases, referees initially granted the claimants' awards for disability benefits and attorney's fees. The respondent, the Republic of the Philippines (Bureau of Public Schools), received notice of these decisions but failed to file appeals within the reglementary period. Subsequently, the respondent filed petitions for relief from judgment beyond the ultimate grace periods allowed by the Commission Rules. Despite these untimeliness, the Workmen's Compensation Commission entertained these petitions and rendered decisions reversing the referees' awards and absolving the respondent from liability. 3. The Petition: The petitioners, Tomas U. Soliven and Eulogia Malijan, seek review of the Workmen's Compensation Commission's decisions through petitions for certiorari. They argue that the Commission lacked jurisdiction to set aside the referees' decisions, which had become final and executory due to the respondent's failure to perfect a timely appeal or file a timely petition for relief from judgment. The petitioners contend that the Commission's decisions were null and void as they were rendered without jurisdiction, citing established doctrines on the finality of judgments and the strict, inextendible nature of grace periods for relief from judgment.
Issue(s)
Whether the respondent commission had jurisdiction to set aside the referees' decisions that had become final and executory. Whether the petitions for relief from judgment were filed within the reglementary periods prescribed by the Commission Rules.
Ruling
The decisions of the respondent commission are set aside, and the referees' decisions in favor of petitioners Tomas U. Soliven and Eulogia Malijan are reinstated. Attorney's fees in L-45381 are increased to P209.57.
Ratio Decidendi
On the jurisdiction of the respondent commission: The Supreme Court reiterated the basic rule of finality of judgments, which is applicable to all, public or private employers. This rule is grounded on public policy and sound practice, ensuring that judgments become final at a definite date. The Court emphasized that the perfection of an appeal within the statutory or reglementary period is mandatory and jurisdictional. Failure to perfect an appeal within the prescribed period renders the decision final and executory, depriving the appellate court of jurisdiction to entertain the appeal. The lapse of the appeal period deprives the courts of jurisdiction to alter the final judgment. On the timeliness of petitions for relief from judgment: The Court clarified that the exception, or "last chance," of a petition for relief from judgment, as provided in the 1973 Commission Rules, must be filed timely within the reglementary period. This period is defined as within 30 days from knowledge/notice of the decision and within 3 months from entry thereof. The Court stressed that this grace period is "absolutely fixed, inextendible, never interrupted, and cannot be subjected to any condition or contingency." It is an act of grace designed to give the aggrieved party another and last chance. Failure to avail of this last chance within the fixed grace period is fatal. In both cases at bar, the petitions for relief were filed beyond the ultimate 30-day grace period, rendering them fatally defective and the commission's entertainment of them an act without jurisdiction.
Main Doctrine
The respondent commission's decisions reversing the referees' awards were null and void for lack of jurisdiction, as the referees' decisions had already become final and executory due to the respondent's failure to appeal within the reglementary period and to file timely petitions for relief from judgment within the prescribed grace periods.