Sison v. Workmen's Compensation Commission
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a claim for death compensation filed by Angeles Vda. de Sison, the widow of the late Pedro Sison, an employee of the Philippine National Railways. Pedro Sison worked for the railway company for many years, eventually becoming a first-class conductor. He went on sick leave in June 1969 due to ill health, complaining of abdominal pain, weight loss, jaundice, and fatigue. An exploratory laparotomy revealed an enlarged liver with metastatic implants and an enlarged pancreas. He died on June 25, 1969, from "hepatic insufficiency," with other contributing causes listed as "Cancer of Ampulla of Vater" and "Liver Cirrhosis." The claim asserts that his fatal illness supervened during his employment and was aggravated by the nature of his work. 2. Procedural History: The claimant filed a Notice and Claim for Compensation on December 21, 1972. A Hearing Officer, Mr. Pedro Pelaez, issued a decision on March 3, 1975, finding the illness compensable and ordering the Philippine National Railways to pay death compensation, burial expenses, and reimbursement for medical expenses. The respondent employer filed a Motion for Reconsideration or Petition to Elevate the Case on April 15, 1975, questioning the evidence and the link between the illness and employment. The claimant argued this motion was filed out of time, asserting the decision had become final and executory. Subsequently, Acting Referee Benjamin R. Perez issued an order on August 27, 1975, dismissing the claim for failure of the claimant to appear at a hearing, despite the prior decision. The claimant's motion for reconsideration of this dismissal was denied, but the case was elevated to the Workmen's Compensation Commission. On December 30, 1975, the Commission affirmed the dismissal order, stating it was unaware of the prior decision by Referee Pelaez and finding no indication the illness arose from employment. 3. The Petition: The petitioner, Angeles Vda. de Sison, seeks review of the Workmen's Compensation Commission's decision dated December 30, 1975, which affirmed the dismissal of her claim. The petition argues that Acting Referee Benjamin Perez acted with grave abuse of discretion in dismissing the claim after a decision on the merits had already been rendered by Referee Pelaez, and that the Commission's affirmation of this dismissal was contrary to law. The core of the petition is that the decision of Referee Pelaez had become final and executory, and the subsequent dismissal and affirmation by the Commission were erroneous and beyond their jurisdiction. The petitioner contends that the respondent employer failed to controvert the claim within the statutory period, waiving all non-jurisdictional defenses, and that the evidence fully supported the compensability of the claim.
Issue(s)
Whether the Workmen's Compensation Commission (WCC) committed grave abuse of discretion in affirming the dismissal order issued by Acting Referee Benjamin R. Perez, despite a prior decision by Hearing Officer Pedro Pelaez that had allegedly become final and executory. Whether the decision of Hearing Officer Pedro Pelaez dated March 3, 1975, had indeed become final and executory, thereby divesting the WCC of jurisdiction to review or affirm a subsequent dismissal order.
Ruling
The Supreme Court set aside the decision of the Workmen's Compensation Commission dated December 30, 1975, and reinstated the decision of Acting Referee Pedro Pelaez dated March 3, 1975, with a modification increasing the attorney's fees. The Court declared the dismissal order by Referee Perez and the WCC's affirmation thereof as null and void.
Ratio Decidendi
On Issue 1: The Supreme Court held that Acting Referee Benjamin Perez acted with grave abuse of discretion in issuing an order of dismissal for failure to prosecute when a prior decision on the merits had already been rendered by Hearing Officer Pedro Pelaez. The Court found no explanation or justification for the duplication of proceedings concerning the same claim and docket number. The records did not show any order vacating the first judgment or instructing Referee Perez to conduct a new hearing. In the absence of proof to the contrary, the presumption is that the first proceeding was regularly performed and should be given preference. Therefore, the second hearing, improperly initiated, rendered the dismissal order void, and the WCC's affirmation of this void order was contrary to law. On Issue 2: The Supreme Court agreed with the petitioner that the decision of Referee Pelaez dated March 3, 1975, had already become final and executory. The respondent employer filed its Motion for Reconsideration or Petition to Elevate the Case on April 15, 1975. The petitioner's opposition pointed out that the respondent allegedly received the decision on October 4, 1974, which would make the April 15, 1975 motion filed beyond the reglementary period for reconsideration. Even if the date of receipt was disputed, the subsequent actions, including the claimant's ex parte motion for execution and the WCC's own letter-demand for payment dated January 26, 1976, indicated that the award had become final and executory. Consequently, the respondent employer was deemed to have abandoned its motion for reconsideration, and the respondent Commission was without authority or jurisdiction to review, revise, or reverse the award granted by Referee Pelaez.
Main Doctrine
The Supreme Court reiterated that once an award granted by a Hearing Officer of the Workmen's Compensation Commission becomes final and executory, the Commission is divested of its jurisdiction to review, revise, or reverse the same. The failure of an employer to controvert a claim within the statutory period constitutes a waiver of all non-jurisdictional defenses, including the argument that the illness was not compensable. Furthermore, the Court emphasized that an illness supervening during the course of employment is presumed to have arisen out of or been aggravated by such employment, and the employer bears the burden of proving otherwise with substantial evidence.