Santos v. Department of Labor
REITERATIONFacts
The Antecedents: Petitioner Lolita Santos was employed as a seamstress by respondent Manila Bay Hosiery Mills Inc. She became disabled from work due to illnesses in 1973 and again in February 1974. She filed claims for compensation for both periods. In the first claim (WC Case No. 147119), an award of P1,707.19 for compensation and medical expenses was granted and paid. In the second claim (WC Case No. 164491), she alleged illnesses of pulmonary tuberculosis, chronic gastritis, and anemia, attributing them to her working conditions. The respondent company denied these illnesses were work-connected. Procedural History: An Acting Referee rendered a decision on October 2, 1975, in WC Case No. 164491, finding petitioner's illnesses to be work-connected and ordering the company to pay disability compensation totaling P6,000.00 (P2,661.12 plus 60% of her average weekly wage until the maximum is reached), reimbursement of medical expenses (P415.30), attorney's fees, and decision fees. The decision was partially executed, with the company paying P3,261.12. However, the company failed to make further payments. Petitioner moved for execution, and a writ was issued but returned unsatisfied as the company claimed to have paid the amount due up to October 2, 1975. Petitioner subsequently moved to enforce weekly payments with the Department of Labor. On July 7, 1977, the Acting Secretary of Labor denied petitioner's motion, stating her illness was cured or arrested based on September 23, 1975 x-ray examinations. Petitioner's motion for reconsideration was denied. The Petition: Petitioner filed a petition for review on certiorari, assailing the July 7, 1977 Order of the Acting Secretary of Labor, arguing that the decision of October 2, 1975, had become final and executory and could not be modified or set aside. The Solicitor General concurred, stating the Acting Secretary committed a reversible error or grave abuse of discretion.
Issue(s)
Whether the Department of Labor, through its Acting Secretary/Minister, committed grave abuse of discretion amounting to lack of jurisdiction by denying petitioner's claim for additional weekly compensation on the ground that her illness had been cured or arrested, despite a prior decision having become final and executory. Whether the petitioner is entitled to claim the entire balance of her disability compensation at once, along with interest, due to the employer's failure to comply with payment obligations.
Ruling
The Supreme Court ruled in favor of the petitioner. The Order dated July 7, 1977, of the Deputy Minister of Labor is SET ASIDE. Respondent-employer Manila Bay Hosiery Mills, Inc. is ordered to pay directly to the petitioner the sum of P2,738.88 plus 12% interest from February 10, 1977, until fully paid.
Ratio Decidendi
On Issue 1: The Supreme Court found that the Department of Labor, through its Acting Secretary/Minister, committed grave abuse of discretion amounting to lack of jurisdiction when it issued the Order dated July 7, 1977. The Court reiterated the well-settled rule in Philippine jurisdiction that a referee's decision in workmen's compensation cases, once it has become final and executory, can no longer be modified or set aside. This principle is not merely a procedural technicality but is grounded in fundamental considerations of public policy and sound practice, which demand that judgments of courts and awards of quasi-judicial agencies attain finality at a definite date fixed by law to ensure stability and prevent endless litigation, even at the risk of occasional error. Since the October 2, 1975 decision had already become final and was partially executed, the Department of Labor had no authority to disturb or modify it, making the subsequent orders denying additional compensation null and void. The Court explicitly cited Ruelan vs. Republic, Soliven vs. WCC, Cruz vs. WCC, and Ramos vs. Republic to underscore this long-established doctrine. On Issue 2: The Supreme Court held that the petitioner was indeed entitled to claim the entire balance of her disability compensation at once, along with accrued interest. This entitlement is mandated by the last paragraph of Section 22 of the Workmen's Compensation Act, as amended, which explicitly provides that "Any failure on the part of the employer to comply with this obligation to pay any of the sums due to the injured laborer or his dependents in accordance with this Act, shall entitle the beneficiary to claim the entire balance of the compensation at one time." Given the respondent employer's failure to make the additional weekly payments as ordered in the final October 2, 1975 decision, the petitioner's claim for the remaining balance of P2,738.88 was legally justified. Furthermore, applying Central Bank Circular No. 416, the Court ordered that a 12% interest be imposed on the said amount from February 10, 1977, which was the date the demand for weekly payments was made on the respondent employer, until the amount is fully paid.
Main Doctrine
A final and executory decision in a workmen's compensation case can no longer be modified or set aside, and any order issued in excess of jurisdiction or with grave abuse of discretion, amounting to lack of jurisdiction, is considered reversible error.