Cariño v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Eriberta R. Cariño, a former teacher in the Bureau of Public Schools, worked from June 30, 1930, until April 15, 1973, when she stopped due to disability. She took sick leave from September 11 to September 30, 1972, due to "acute gastroenteritis, secondary to anemia and infection." Procedural History: On October 14, 1975, the Acting Referee awarded petitioner P5,677.50 in disability compensation benefits, plus P43.75 weekly until cured but not exceeding P6,000.00, finding that petitioner contracted hypertension, rheumatism, acute gastroenteritis, and anemia, all supervening in the course of her employment. The respondent Republic of the Philippines received this decision on October 21, 1975. On November 24, 1975 (the 34th day), the Republic filed a petition to elevate records for relief from judgment, alleging it was prevented from appealing by accident and/or excusable negligence. The Workmen's Compensation Commission (WCC) reversed the Acting Referee's decision, absolving the Republic. The Petition: Petitioner filed a petition for certiorari, praying for the setting aside of the WCC decision, reinstatement of the Acting Referee's decision, an increase in attorney's fees, and an increase in the disability benefit award. The sole ground relied upon is that the WCC had no authority to review a final and executory decision of the Acting Referee.
Issue(s)
Whether or not the petition to elevate records for relief from judgment was filed on time and for causes allowed by law. May the decision or award issued by the Acting Referee in the original case still be set aside and substituted with another by the WCC after the lapse of the period for the filing of a petition to elevate records for relief from judgment?
Ruling
The Supreme Court reversed and set aside the decision of the respondent Workmen's Compensation Commission. The respondent Bureau of Public Schools was directed to pay petitioner Eriberta Cariño P6,000.00 in disability compensation, attorney's fees equivalent to 10% of the award, reimbursement for medical and hospital services duly evidenced by receipts, and P61.00 as administrative fee.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the petition to elevate records for relief from judgment was not filed on time and for causes allowed by law. Sections 1 and 3 of Rule 22 of the WCC Rules require such petitions to be filed within thirty (30) days after the petitioner learns of the decision. In this case, counsel for the respondent received the Acting Referee's decision on October 21, 1975, making the 30-day period expire on November 20, 1975. However, the petition for relief was filed only on November 24, 1975, which was the 34th day. The Court emphatically stated that 'pressure of work' by counsel is not a valid excuse for the late filing of a required pleading, citing Pantoja vs. ECC and Bilbao vs. Rep. This reinforces the strict interpretation of reglementary periods and the principle that counsel's negligence binds the client, particularly in the absence of valid 'fraud, accident, mistake or excusable negligence' as contemplated by the rules. The respondent was also deemed to have waived its right to interpose defenses by failing to appear at the original hearing despite notice. On Issue 2: The Supreme Court held that the decision or award issued by the Acting Referee could no longer be set aside by the WCC after the lapse of the reglementary period for filing a petition to elevate records for relief from judgment. The decision of the Acting Referee became final and executory on November 20, 1975, thirty days after its receipt by respondent's counsel. The Court reiterated that the statutory periods for appeal and petitions for relief from judgment are jurisdictional and not merely matters of form, dealing with the very jurisdiction of the Commission. Citing La Paz Martinez vs. WCC, et al., the Court underscored that it was patent from the record that the decision-award had long become final and executory. Furthermore, the Court cited Soliven vs. Workmen's Compensation Commissioner and Amado T. Cruz vs. Compensation Commission & Republic, affirming the basic rule of finality of judgments, which applies indiscriminately to all, grounded on fundamental considerations of public policy and sound practice, ensuring that judgments of courts and quasi-judicial agencies become final at a definite date fixed by law. Therefore, the WCC acted beyond the scope of its authority in taking cognizance of the belated petition.
Main Doctrine
The statutory periods for appeal and for petitions for relief from judgment are not merely matters of form but of substance, dealing as they do with the very jurisdiction of the commission. A petition for relief from judgment filed beyond the reglementary period, which is 30 days after knowledge of the decision and not more than three months after entry thereof, renders the decision final and executory, and the commission loses jurisdiction to set it aside.