Soliweg v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Pogong Soliweg filed a claim for compensation against the Republic of the Philippines (Office of the President) due to pulmonary tuberculosis, an illness he alleged was contracted as a result of and during his employment. The respondent controverted the claim, asserting the illness was not compensable and the claim was filed out of time. Procedural History: The Regional Referee ruled in favor of the claimant, ordering the respondent to pay compensation benefits, medical expenses, and attorney's fees. The Office of the Solicitor General's motion to elevate the case to the Workmen's Compensation Commission (WCC) was initially denied for being filed out of time and unverified. Despite subsequent motions and orders, the WCC ultimately reversed the Referee's decision on April 25, 1975, a decision that had become final and executory. A motion for reconsideration by the petitioner was denied. The Petition: This petition seeks review of the WCC's decision, arguing that the WCC lacked jurisdiction to issue its decision as the Referee's ruling had become final and executory. The petitioner contends that the WCC's decision is a nullity. Furthermore, the petition asserts that the petitioner's illness, pulmonary tuberculosis, is compensable given the nature of his work as a gardener, which exposed him to elements that could have weakened his resistance, and that his ailment supervened during his employment, creating a presumption of compensability.
Issue(s)
Whether the Workmen's Compensation Commission had jurisdiction to render its decision dated April 25, 1975, reversing the Referee's decision. Whether the petitioner's illness of pulmonary tuberculosis is compensable under the Workmen's Compensation Act.
Ruling
The decision of the Workmen's Compensation Commission is set aside, and the decision of the Chief, Workmen's Compensation Section at Baguio City dated March 22, 1973, is reinstated.
Ratio Decidendi
On the issue of jurisdiction: The Court held that the decision of the Chief of the Sub-Regional Office of the Department of Labor at Baguio City had become final and executory because the motion to elevate the case to the Workmen's Compensation Commission for review was filed by the Republic of the Philippines on May 11, 1973, which was more than one month after the Office of the Solicitor General received the Referee's decision on April 2, 1973. The Chairman of the WCC correctly denied the motion to elevate on the grounds that the respondent failed to file a motion for reconsideration or petition for review within the reglementary period and that the motion to elevate was not verified and filed beyond the thirty-day period. Consequently, the WCC had no jurisdiction to issue its decision dated April 25, 1975, reversing the Referee's decision, rendering the WCC's decision a nullity that could be assailed directly or collaterally. The Court cited Abbain vs. Chua and Gomez vs. Concepcion to emphasize that a void judgment is a lawless thing that can be ignored or attacked at any time, and the limited periods for relief under Rule 38 are inapplicable to such judgments. On the compensability of the illness: The Court found the petition meritorious on the ground that the sickness of the petitioner was compensable. The evidence showed that Pogong Soliweg was found physically fit before his employment as a gardener. His duties involved operating a lawn mower and cutting grass, even during the rainy season, requiring him to wear a raincoat. He suffered an ailment diagnosed as pulmonary tuberculosis during his employment in 1969, which was known to his superior. The Court reiterated the presumption that an ailment supervening during employment is compensable. The nature of his work exposed him to the elements, which could have weakened his body's resistance, thereby giving rise to or aggravating his pulmonary tuberculosis. The Referee's computation of compensation benefits under Sections 13 and 14 of the Act was found to be correct.
Main Doctrine
A decision that has become final and executory can no longer be reviewed or modified by any court or quasi-judicial body, as it is considered a nullity if acted upon beyond the reglementary period.