Lim v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Jose Y. Lim, employed with the Department of Justice since March 23, 1945, and holding the position of Assistant Chief State Prosecutor upon his retirement on November 25, 1972, at age 60, filed a "notice of sickness and claim for disability compensation" on May 16, 1974. He claimed that hypertension and essential hypertensive heart disease, sustained in the course of his employment, led to his early retirement. Medical reports indicated a "10% permanent partial non-scheduled disability" due to these ailments. Procedural History: A Hearing Officer rendered an award on October 20, 1975, in favor of Lim, ordering the Republic of the Philippines (Department of Justice) to pay P6,000.00 as compensation and P61.00 as administrative fee. The claim for reimbursement of medical expenses was held in abeyance pending submission of official receipts. The Office of the Solicitor General received a copy of this award on November 5, 1975. On January 7, 1976, the Solicitor General filed a "Petition to elevate records for relief from judgment" with the Workmen's Compensation Commission (WCC). The WCC set aside the referee's award, stating that the service-connected illness was not proved, the medical evidence was uncorroborated, and hypertension per se is not compensable as it is a result of aging. The Petition: Claimant Jose Lim filed a petition with the Supreme Court, arguing that the WCC decision was rendered without jurisdiction because the referee's award had become final and executory due to the employer's failure to file a motion for reconsideration or review within 15 days. He also contended that the employer's Petition for Relief from Judgment was filed beyond the periods provided in Rule 38 of the Rules of Court.
Issue(s)
Whether the referee's award of October 20, 1975, had become final and executory. Whether the Workmen's Compensation Commission had jurisdiction to set aside the referee's award. Whether the Petition for Relief from Judgment was filed within the reglementary period.
Ruling
The Supreme Court set aside the decision of the respondent Commission and reinstated the referee's award. The Court ordered the Department of Justice to pay Jose Y. Lim P6,000.00 as disability compensation plus P1,585.00 for medical expenses, P600.00 to his counsel for the appeal, and P61.00 as administrative fee to the Workmen's Compensation Fund.
Ratio Decidendi
On the finality of the referee's award: The Court held that the referee's award of October 20, 1975, was not interlocutory but a definitive judgment that finally disposed of the basic claim for disability compensation. The referee made findings of "essential ultimate facts" regarding the claimant's illness, its relation to his employment, the resulting disability, and the lack of employer dispute. The reservation for the resolution of medical expense reimbursement did not convert the award into an interlocutory order, as it was a mere incident to the basic claim. Citing Halili vs. Court of Industrial Relations, the Court reiterated that an interlocutory order is something intervening that does not decide the whole controversy, whereas the referee's award decided the rights of the parties on the claim for disability compensation with finality. On the jurisdiction of the Workmen's Compensation Commission: Considering the referee's award was final and appealable, it became executory upon the employer's failure to file an appeal within the 15-day reglementary period. The award was received on November 5, 1975, and the 15-day period ended on November 20, 1975. The employer's subsequent Petition for Relief from Judgment, filed on January 7, 1976, was filed beyond the 30-day period from notice and the three-month period from rendition of the award, as required by Section 3, Rule 22 of the WCC Rules. These periods must concur, and failure to meet them deprives the Commission of jurisdiction to review the referee's decision. The Court emphasized that this rule of finality applies regardless of whether the employer is public or private. On the timeliness of the Petition for Relief from Judgment: The employer's argument that the 30-day period should be counted from December 12, 1975 (receipt of a later order on medical expenses) was rejected. The Court clarified that the decision of October 20, 1975, was not merely partial but a final disposition of the core claim. Therefore, the 15-day period for appeal commenced upon receipt of the October 20, 1975 award on November 5, 1975. The Petition for Relief from Judgment, filed on January 7, 1976, was thus filed beyond the prescribed periods, rendering it too late to confer jurisdiction on the respondent Commission. The Court also noted that the claim for disability compensation was valid and meritorious under the principles of presumption of compensability, non-controversion, and optional retirement due to ailment.
Main Doctrine
A referee's award that finally disposes of the basic claim for disability compensation, even if it reserves pronouncement on incidental matters like reimbursement of medical expenses, constitutes a definitive judgment and is not interlocutory. Failure to file a motion for reconsideration or review within the reglementary period renders the award final and executory, precluding the filing of a petition for relief from judgment beyond the prescribed periods.