Ulibas v. Republic
REITERATIONFacts
The Antecedents: Cecilia V. Ulibas, a classroom teacher from June 1, 1930, to November 21, 1968, filed a claim for disability compensation benefits. During her employment, she developed chronic poly articular rheumatism, chronic laryngitis, anemia-hypotension, and chronic weeping eczema, which led to loss of voice and general physical weakness. These ailments, which began manifesting in 1966, eventually compelled her to retire at the age of 60 due to her inability to perform her duties effectively. Procedural History: Ulibas filed her claim with the Department of Labor's Regional Office No. 4. An acting referee ruled in her favor, awarding disability compensation, attorney's fees, and administrative fees. The Office of the Solicitor General, representing the respondent Bureau of Public Schools, filed a petition to elevate the records for relief from judgment beyond the 15-day reglementary period, citing heavy workload. The Workmen's Compensation Commission reversed the referee's decision, absolving the employer. This reversal prompted Ulibas to file the present petition. The Petition: Ulibas petitions this Court to set aside the decision of the Workmen's Compensation Commission. Her primary argument is that the referee's award had become final and executory due to the employer's failure to file a motion for reconsideration or an appeal within the prescribed 15-day period. She contends that the employer's justification of a heavy workload for the delay is insufficient, citing precedent that mere pressure of work is not an excusable ground for such delay and that a petition for relief requires an affidavit of merits, which was absent. Furthermore, she asserts the meritorious nature of her claim, arguing her ailments arose from or were aggravated by her employment as a teacher.
Issue(s)
Whether the petition for relief from judgment filed by the Office of the Solicitor General was timely and meritorious. Whether the petitioner's ailments are compensable under the Workmen's Compensation Act.
Ruling
The Supreme Court set aside the decision of the respondent Commission and reinstated the award of the acting referee in favor of petitioner Cecilia Ulibas, with a modification increasing the attorney's fees. The Court ruled that the petition for relief from judgment was not timely filed and lacked an affidavit of merits, and that the petitioner's illnesses were compensable.
Ratio Decidendi
On the timeliness and merit of the petition for relief from judgment: The Court held that the petition filed by the Office of the Solicitor General was filed outside the 15-day reglementary period for filing a motion for reconsideration or appeal. The Court found the justification of "volume and heavy pressure of work" to be untenable, citing the precedent set in Ranada, et al. vs. WCC and Republic of the Philippines. For a petition for relief from judgment to be meritorious, it must be accompanied by an affidavit of merits showing the facts constituting the petitioner's good and substantial cause of action or defense. Mere pressure of work cannot be considered a valid excuse for not filing within the reglementary period, and the negligence committed cannot be considered excusable. The Court emphasized that the government's argument in this case was the same one rejected in Ranada, making the latter case controlling. On the compensability of the petitioner's ailments: The Court found the claim for disability compensation benefits to be meritorious and justified. The evidence showed that in the course of petitioner's employment as a teacher, she developed chronic poly articular rheumatism, chronic laryngitis, anemia-hypotension, and chronic weeping eczema. These ailments resulted in loss of voice and general physical weakness, compelling her to retire. The Court rejected the respondent's contention that the petitioner stopped working by choice to enjoy retirement benefits, stating it was without basis. The Court reiterated the principle that disability occurs when an employee is unable to perform work due to physical inability, leading to a loss or diminution of earning power due to an injury arising out of and in the course of employment. Furthermore, the Court invoked the legal presumption under Section 44 of the Workmen's Compensation Act, as amended, that an illness which supervened during employment either arose out of or was at least aggravated by the employment, thus shifting the burden of proof to the employer. The Court cited Abana vs. Quisumbing and Belmonte vs. W.C.C. to support the principle that it is not required for employment to be the sole factor in the aggravation of an illness; it is enough that it contributed even in a small degree. The Court concluded that the petitioner's work as a classroom teacher directly caused and aggravated her ailments.
Main Doctrine
A petition for relief from judgment filed by the Office of the Solicitor General is untenable if not accompanied by an affidavit of merits and if the delay in filing the appeal is solely due to the pressure of work, which is not considered excusable negligence. Furthermore, illnesses contracted during employment are presumed to have arisen out of or were aggravated by such employment, shifting the burden of proof to the employer.