Pajarillo v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Visitacion N. Pajarillo, a public school teacher for over 28 years, retired on July 1, 1973. She filed a claim for compensation due to chronic cataract (both eyes) and diabetes mellitus, illnesses she contracted and/or were aggravated during her employment. She stopped working on June 4, 1973, due to these illnesses. Procedural History: The Chief Referee issued an award on August 26, 1974, finding the illnesses compensable and aggravated by employment, and declaring the claim uncontroverted. The Solicitor General received the award on September 16, 1974. He filed a motion for extension to file a motion for reconsideration on October 3, 1974, which was granted on December 2, 1974. Subsequently, on December 4, 1974, he filed a motion to set aside the award, alleging denial of due process and non-compensability. The Chief Referee denied this motion but elevated the records to the respondent Commission. On October 9, 1975, the respondent Commission reversed the award, holding the illnesses not compensable and not causally related to petitioner's work. The Petition: Petitioner filed a motion for reconsideration with the Commission, which was advised to appeal to the Supreme Court. Petitioner then filed a petition for review with the Supreme Court.
Issue(s)
Whether the respondent Commission gravely abused its discretion when it reversed the award of the Chief Referee, and whether the respondent Commission had jurisdiction to review the award of the Chief Referee which had allegedly become final and executory. Whether the petitioner's illnesses (chronic cataract and diabetes mellitus) are compensable under the Workmen's Compensation Act.
Ruling
The Supreme Court ruled in the affirmative on the issue of grave abuse of discretion. The decision of the respondent Commission was reversed and set aside. The respondent employers were ordered to pay petitioner P6,000.00 as disability benefits, her medical expenses, and attorney's fees, and to pay administrative fees to the successor of the defunct Commission.
Ratio Decidendi
On the issue of grave abuse of discretion and jurisdiction: The Supreme Court held that the respondent Commission gravely abused its discretion in reversing the award of the Chief Referee. The award had become final and executory because the Solicitor General failed to timely file a motion for reconsideration or a motion to set aside the award. The Solicitor General received the award on September 16, 1974. His motion for extension to file a motion for reconsideration was filed on October 3, 1974, which was beyond the 15-day reglementary period. The subsequent granting of the extension by the Chief Referee did not cure the lapse, as the motion for extension must be filed within the original period. Furthermore, the motion to set aside the award was filed 99 days after receipt of the award, which is also beyond the prescribed period for a petition for relief from judgment. Therefore, the Commission had no jurisdiction to review the award which had already attained finality. On the issue of compensability: The Supreme Court found that the respondent employers failed to discharge their burden of overthrowing the presumption of compensability. The petitioner's illnesses and disability supervened in the course of her employment. The claim was also not effectively controverted by the respondent employers, which is fatal to any defense they might interpose. The Court noted that the "Report of the Division of Camarines Norte Committee on Workmen's Compensation Cases" found the claim meritorious and justifiable, stating that the ailment was aggravated by the nature of her work. The Court reiterated that it is not required that employment be the sole factor; it is enough if it contributed even in a small degree. The Court also cited the Magna Charta for Public School Teachers, which mandates that the effects of physical and nervous strain on a teacher's health shall be recognized as a compensable occupational disease.
Main Doctrine
A decision or award that has become final and executory can no longer be reviewed by the Commission, and any attempt to do so constitutes grave abuse of discretion. Furthermore, the failure to timely controvert a claim or to perfect an appeal within the reglementary period is fatal to any defense the employer may interpose.