Republic v. Pollosco
REITERATIONFacts
1. The Antecedents: Patrocinio Pollosco, an employee of the Bureau of Public Highways, contracted pulmonary tuberculosis during his employment. Upon reaching the age of 63, he ceased working due to his illness and subsequently filed a claim for disability and medical benefits. 2. Procedural History: The claim was initially heard by an Acting Referee in Regional Office No. 4, who rendered a decision on December 29, 1966, ordering the Republic of the Philippines to pay Pollosco P2,101.84 in disability compensation and P5,100.00 for medical expenses. The Republic moved for reconsideration regarding the medical expenses, while Pollosco sought partial execution for the disability compensation. The Workmen's Compensation Commission (WCC) reviewed the case and, in a decision dated May 31, 1968, affirmed the award but modified it by increasing the disability compensation to P4,000.00 and reducing the medical expense reimbursement to P875.00, also ordering attorney's fees and WCC fund payments. The WCC en banc denied the Republic's motion for reconsideration. 3. The Petition: The Republic of the Philippines filed a petition for certiorari with the Supreme Court, assailing the WCC's decision. The petitioner argued that the WCC erred in modifying the Acting Referee's decision regarding disability compensation, which had become final and executory, and in disregarding the Court's ruling in Hernandez vs. Workmen's Compensation Commission. The petitioner contended that the award of P2,101.84 was final and could not be increased, and that the WCC's computation of disability benefits was erroneous.
Issue(s)
Whether the Workmen's Compensation Commission erred in modifying the decision of the Acting Referee regarding disability compensation, which had allegedly become final and executory. Whether the Workmen's Compensation Commission erred in disregarding the ruling in Hernandez v. Workmen's Compensation Commission, et al., G.R. No. L-20202, May 31, 1965. Whether the Acting Referee's computation of P2,101.84 for disability compensation was correct. Whether the principle established in Hernandez v. Workmen's Compensation Commission regarding compensation payments premised on loss or impairment of earning capacity was correctly applied.
Ruling
The Court set aside the portion of the WCC decision ordering the petitioner to pay P4,000.00 as disability compensation and affirmed the Acting Referee's decision ordering the petitioner to pay P2,101.84 as disability compensation. The Court also affirmed the WCC's award for medical expenses and other fees.
Ratio Decidendi
On the modification of the award: The Court held that the award for disability compensation in the amount of P2,101.84 had become final and executory because no appeal was taken by either party on this specific portion. The claimant had even moved for the execution of this part of the decision, and the petitioner was directed to pay. The basic rule of finality of judgments is applicable to all, including public employers, and such awards, once final, cannot be modified by the Workmen's Compensation Commission. The Commission clearly erred in increasing the disability compensation award to P4,000.00. On disregarding Hernandez v. Workmen's Compensation Commission: The Court found that the WCC's modification disregarded the established jurisprudence in Hernandez v. Workmen's Compensation Commission. On the computation of the award: The Court found the Acting Referee's computation of P2,101.84 to be correct. The claimant, having been disabled for labor due to illness and compelled to retire prematurely at age 63, was entitled to disability compensation for two years. The computation was based on 60% of his average weekly wage for 104 weeks, consistent with Act 3428, as amended, and the ruling in Hernandez v. Workmen's Compensation Commission. The Acting Referee correctly calculated this amount based on the claimant's last pay rate of P146.00 a month. On the application of Hernandez v. Workmen's Compensation Commission: The Court reiterated the principle established in Hernandez v. Workmen's Compensation Commission, which states that compensation payments premised on loss or impairment of earning capacity due to illness cannot extend beyond the compulsory retirement date of an employee. This principle was correctly applied by the Acting Referee in limiting the compensation period.
Main Doctrine
The Workmen's Compensation Commission erred in modifying a decision that had become final and executory regarding disability compensation. Awards that have become final and executory cannot be modified by the Commission, as the basic rule of finality of judgments applies to all, regardless of whether the employer is public or private.