Ligason v. Workmen's Compensation Commission
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a claim for disability benefits filed by Cirila Ligason against the Republic of the Philippines, specifically the Bureau of Public Schools, under the Workmen's Compensation Act. The claim was initially adjudicated by a referee. 2. Procedural History: The Acting Labor Referee issued an award in favor of petitioner Cirila Ligason, granting disability benefits and attorney's fees. This award was subsequently reviewed by the respondent Workmen's Compensation Commission. The Commission's decision, however, led to the present petition before the Supreme Court. 3. The Petition: Petitioner Cirila Ligason, through her counsels, filed a motion for reconsideration and correction of her surname's spelling in the Court's decision. Additionally, the motion sought to amend the award of attorney's fees to reflect 10% of the P6,000.00 recovery, as stipulated by Section 31 of the Workmen's Compensation Act, as amended. The Court found the motion meritorious and authorized the correction of the surname and increased the attorney's fees.
Issue(s)
Whether the Court may correct a clerical error in the spelling of a party's surname in its decision. Whether the attorney's fees awarded should be adjusted to comply with the statutory percentage.
Ruling
The Court granted the Motion for Reconsideration. It authorized the Clerk of Court to correct the spelling of the petitioner's surname from "Legason" to "Ligason" in the January 31, 1977 decision. The dispositive portion of the decision was amended to increase the attorney's fees from P300.00 to P600.00.
Ratio Decidendi
On Whether the Court may correct a clerical error in the spelling of a party's surname in its decision: The Court found the motion for reconsideration meritorious regarding the correction of the mis-spelling of the petitioner's surname. The Court acknowledged that the surname "Ligason" was consistently used by the petitioner in her pleadings and other documents of record. The Clerk of Court was authorized to make the necessary correction in the Court's decision to accurately reflect the petitioner's surname. This action falls within the inherent power of the Court to correct clerical mistakes in its judgments to ensure accuracy and prevent injustice, without altering the substantial merits of the case. On Whether the attorney's fees awarded should be adjusted to comply with the statutory percentage: The Court also addressed the prayer for attorney's fees. Petitioner's counsels argued that attorney's fees should be 10% of the P6,000.00 recovery, as provided by Section 31 of the Workmen's Compensation Act, as amended. The original award for attorney's fees was P300.00. By increasing the award to P600.00, the Court effectively granted the 10% statutory attorney's fees based on the P6,000.00 disability benefits. This amendment to the dispositive portion of the decision reflects the Court's adherence to the statutory provisions governing attorney's fees in workmen's compensation cases.
Main Doctrine
The Supreme Court, in resolving a motion for reconsideration, can correct clerical errors such as misspellings in party names to ensure the accuracy of its records and judgments. Furthermore, the Court affirmed the award of attorney's fees as provided by law, adjusting the amount to reflect the statutory percentage of the disability benefits granted.