Villanueva v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Benjamin Z. Villanueva, an employee of the Land Transportation Commission, was declared totally and permanently disabled by the GSIS and approved for retirement at age 60, effective February 1, 1974. Two days later, on February 3, 1974, he experienced illness symptoms, was hospitalized, and diagnosed with various ailments including upper respiratory tract infection, viral encephalomyelitis, ischio-rectal abscess, and fistula en anu. He was confined from February 3, 1974, to March 7, 1974, and suffered a relapse from December 24, 1974, to January 6, 1975. On September 13, 1974, he filed a claim for disability benefits under the Workmen's Compensation Act against the Republic of the Philippines. Procedural History: Acting Referee Jesus B. Gador rendered a decision on October 30, 1975, finding a substantial connection between petitioner's employment and his disease and ordering the Republic to pay disability compensation, medical expense reimbursement, attorney's fees, and administrative fees. The Office of the Solicitor General (OSG), representing the Republic, received this decision on December 16, 1975. On January 17, 1976, the Republic filed a "Petition to Elevate Records for Relief from Judgment" with the Workmen's Compensation Commission (WCC), citing excusable negligence that prevented a timely appeal. The WCC, despite petitioner's opposition, accepted the petition and, on February 18, 1976, reversed the referee's award, ruling that no employer-employee relationship existed at the time of the alleged illness due to the petitioner's prior retirement. The Petition: Petitioner Benjamin Z. Villanueva (deceased, substituted by his wife Beata Tabaño) filed a petition for review seeking the reinstatement of the Acting Referee's decision. The petition raises two primary legal questions: first, whether the WCC acquired appellate jurisdiction despite the Republic's failure to perfect an appeal within the statutory period, and second, whether the WCC's decision reversing the referee's award was adequately supported by evidence and applicable law.
Issue(s)
Whether the Workmen's Compensation Commission acquired appellate jurisdiction over the case despite the respondent Republic's failure to file a petition for review within the 15-day reglementary period. Whether the 'volume and pressure of work' cited by the Office of the Solicitor General constitutes 'excusable negligence' sufficient to warrant relief from judgment.
Ruling
The Supreme Court ruled that the respondent Commission erred in taking cognizance of the Republic's petition for relief from judgment. The Acting Referee's decision had already become final and executory due to the Republic's failure to file a petition for review or motion for reconsideration within the reglementary period. Consequently, the Commission had no jurisdiction to set aside the referee's decision. The Court reinstated the Acting Referee's decision with a modification increasing the attorney's fees.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the award made by the Acting Referee had already become final and executory by the time the Office of the Solicitor General (OSG) filed its petition to elevate the records on January 17, 1976. Under Section 1, Rule 19 of the Revised Rules of the Workmen's Compensation Commission and Section 49 of the Workmen's Compensation Act, the period for reconsideration or review expires 15 days after receipt of the decision. Since the OSG received the decision on December 16, 1975, the decision became final on December 31, 1975. The Court emphasized that the respondent Commission has no jurisdiction to set aside a decision that has already attained finality. Jurisdiction is lost by the lapse of the reglementary period, and any subsequent action by the Commission is void. Therefore, the referee's decision constitutes the 'law of the case' and is beyond the reach of appellate review. On Issue 2: The Court held that 'volume and pressure of work' does not constitute the 'excusable negligence' required for the equitable remedy of relief from judgment. Citing the case of Ranada v. WCC, the Court observed that mere pressure of work is a common excuse that does not justify the failure to file a motion for reconsideration or a request for extension. The Court noted that the OSG has a large staff of trial attorneys who could have attended to the case or filed a simple request for postponement. Relief from judgment is an exceptional remedy that is only available if the sine qua non conditions—fraud, accident, mistake, or excusable negligence—are clearly established. Because the negligence of the trial attorney was deemed 'pure negligence' and not excusable, there was no valid ground to grant relief. Consequently, the WCC committed a reversible error in entertaining the OSG's petition and reversing a final award.
Main Doctrine
A petition for relief from judgment under Rule 22 of the Revised Rules of the Workmen's Compensation Commission must be filed within the reglementary period for appeal or reconsideration, and must be accompanied by affidavits showing fraud, accident, mistake, or excusable negligence, and a good and substantial defense. Mere pressure of work is not considered excusable negligence.