Vega v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Carmelita E. Vega, a public school teacher, was granted disability compensation benefits by a Hearing Referee for an ailment diagnosed as ectopic pregnancy, complicated with hypertension and urinary tract infection, which necessitated a hysterectomy and caused her disability for labor. The award included compensation for disability, reimbursement of medical and hospital expenses, and an administrative fee. Procedural History: The respondent Commission reversed the Hearing Referee's award and dismissed the claim. This reversal occurred after the Solicitor General failed to file a timely appeal from the referee's award, instead filing a Petition to Elevate the Records for Relief from Judgment, alleging "volume and heavy pressure of work" as the reason for the delay. The Commission ruled that ectopic pregnancy was not compensable under the law and that there was no proof of hypertension complications leading to incapacity. The Petition: Petitioner filed the instant petition, assailing the Commission's decision as contrary to law, arguing that the Commission lost its appellate power to review the referee's award which had become final and executory.
Issue(s)
Whether the Workmen's Compensation Commission (WCC) committed grave abuse of discretion and acted without jurisdiction in reversing the award of the Hearing Referee after it had already become final and executory. Whether the petitioner's illness is compensable under the Workmen's Compensation Act (WCA) notwithstanding the respondent's late controversion and the nature of the ailment.
Ruling
The Supreme Court set aside the decision of the Workmen's Compensation Commission and reinstated the award rendered by the Hearing Referee in toto.
Ratio Decidendi
On Issue 1: The Court ruled that the perfection of an appeal within the reglementary period is mandatory and jurisdictional. Citing 'Cruz vs. Workmen's Compensation Commission,' the Court reaffirmed that the rule of finality of judgments applies indiscriminately to both public and private employers as it is grounded on fundamental considerations of public policy. Since the Solicitor General (OSG) received notice of the award on November 11, 1975, and did not interpose an appeal within 15 days, the award became final and executory by operation of law. The OSG's invocation of 'volume and heavy pressure of work' was rejected as a valid ground for relief from judgment, as it does not constitute 'excusable negligence.' Consequently, the WCC did not acquire appellate jurisdiction, and its decision reversing the final award was null and void. On Issue 2: The Court maintained that even if the merits were considered, the WCC erred in disregarding the doctrine of non-controversion. Under the Workmen's Compensation Act (WCA), the failure of the employer to timely file a notice of controversion constitutes a waiver of all non-jurisdictional defenses and an admission of compensability. Furthermore, since the illness supervened during the course of petitioner's employment as a teacher, there arises a rebuttable presumption that the illness arose out of or was aggravated by the nature of her employment. The burden to show by substantial evidence to the contrary lies with the employer, a burden which the Republic failed to discharge in this case. Therefore, the claimant's right to compensation was already 'impregnable' due to the employer's inaction and the legal presumption of compensability.
Main Doctrine
The Workmen's Compensation Commission loses appellate power to review a decision of a hearing officer that has lapsed into finality due to failure to perfect an appeal within the reglementary period. A petition for relief from judgment grounded solely on 'volume and heavy pressure of work' is not sufficient to set aside the finality of the award.