Cueto v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Odon Cruz Cueto was employed by the Board of Liquidators from November 24, 1951, until March 27, 1974, when he was compelled to leave due to a cerebral stroke rendering him totally and permanently disabled. He filed a claim for compensation due to "cerebral thrombosis hypertension, arteriorscierosis" which he alleged supervened in the course of his employment. Procedural History: Regional Office No. 4 granted Cueto disability compensation of P6,000.00 and medical expenses of P12,071.13. The employer, through the Solicitor General, filed a motion for reconsideration solely concerning the medical expenses. The referee subsequently reduced the medical expenses award to P3,098.02. The employer then filed a "Motion to Set Aside Decision," alleging lack of jurisdiction due to improper service of process. This motion was denied, and the case was elevated to the Workmen's Compensation Commission (WCC). The WCC modified the referee's decision, reducing disability compensation to P255.40 and medical expenses to P2,718.85. The Petition: Cueto filed a Petition for Review, arguing that the WCC acted without or in excess of jurisdiction because the referee's awards of April 14, 1975 (disability) and October 30, 1975 (medical expenses) had become final and executory. The Solicitor General contended that the elevation of the case to the WCC en banc opened the entire claim for re-examination.
Issue(s)
Whether the Workmen's Compensation Commission acted without or in excess of jurisdiction when it modified the referee's award for disability compensation. Whether the referee's award for medical expenses, after reconsideration, had become final and executory.
Ruling
The Supreme Court set aside the decision of the respondent Commission and reinstated the referee's decisions of April 14, 1975, and October 30, 1975. The Republic of the Philippines (Board of Liquidators) was ordered to pay Odon Cruz Cueto P6,000.00 as disability compensation and P3,098.02 as reimbursement for medical expenses, totaling P9,098.02, plus attorney's fees and administrative fees.
Ratio Decidendi
On the issue of whether the Workmen's Compensation Commission acted without or in excess of jurisdiction when it modified the referee's award for disability compensation: The Court held that the Solicitor General's motion for reconsideration explicitly prayed for reconsideration only concerning the reimbursement of medical expenses. This motion did not dispute the validity of the P6,000.00 award for disability compensation. Consequently, the award for disability compensation became final and executory for lack of any objection thereto. The Court emphasized that Section 49 of the Workmen's Compensation Act requires that every petition for review, including a motion for reconsideration, must specify in detail the particular errors and objections. Matters not objected to acquire finality and cannot be reviewed by the Commission en banc. The Court cited Ruelan vs. Republic of the Philippines to support the principle that an appellate body should not reverse an award when the only issue for review was the amount of compensation, and the compensability itself was no longer in issue. On the issue of whether the referee's award for medical expenses, after reconsideration, had become final and executory: The Court found this argument to have legal basis. The Office of the Solicitor General received a copy of the referee's award of October 30, 1975, on November 17, 1975. However, no motion for reconsideration was filed within the prescribed 15-day period. Instead, a "Motion to Set Aside Decision" was filed on December 5, 1975, which was too late. Furthermore, this motion was predicated on a misapprehension of facts, specifically the claim that the Regional Office had not acquired jurisdiction over the employer because the notice of claim was not furnished to the Solicitor General. The records clearly showed that the Solicitor General had received the notice of claim on May 29, 1974, and had participated in the proceedings through counsel. Therefore, the employer's motion was considered a "mere scrap of paper" that did not validly confer jurisdiction on the Commission to review a final award.
Main Doctrine
Matters not objected to in a motion for reconsideration or petition for review acquire finality and can no longer be the object of review by the Commission en banc, as Section 49 of the Workmen's Compensation Act requires that petitions for review specify in detail the particular errors and objections.