Relente v. Republic of the Philippines
REITERATIONFacts
The Antecedents: Consolacion F. Relente, a 60-year-old public school teacher with 39 years and 7 months of service, filed a claim for compensation on March 18, 1975, for "bouts of moderate to severe dizziness, headache and pain at the back of (her) neck" due to over-fatigue in her teaching job, which she noticed as early as January 1971. She was diagnosed with "essential hypertension" and "chronic hypertensive vascular disease" and spent P2,610.00 for treatment, purchasing hypertension medication for seven years. Procedural History: The Workmen's Compensation Unit in Olongapo City awarded Mrs. Relente P8,200.00 for permanent total disability and reimbursement of medical expenses on November 14, 1975, assuming the Bureau of Public Schools failed to controvert the claim. The Office of the Solicitor General (OSG) and the Department of Education and Culture were notified on November 24, 1975. The OSG filed a petition for relief from judgment on February 16, 1976, almost three months later, alleging that due to volume and pressure of work, they failed to file a timely motion for reconsideration. The Workmen's Compensation Commission (WCC) set aside the award and dismissed the claim, concluding that Mrs. Relente retired due to old age and failed to sufficiently prove her disability was work-connected. The Petition: Mrs. Relente received the WCC decision on January 17, 1978, and appealed to the Supreme Court, arguing that the November 14, 1975 award had become final and executory, and the WCC lacked jurisdiction to review it.
Issue(s)
Whether the Workmen's Compensation Commission had jurisdiction to set aside a final and executory award. Whether the Solicitor General's petition for relief from judgment was based on valid grounds. Whether there was sufficient evidence to prove that Mrs. Relente's illness was work-connected or work-aggravated. Whether the respondent bureau validly controverted the petitioner's claim, and the effect of such controversion or lack thereof.
Ruling
The Supreme Court reversed and set aside the decision of the respondent Commission and affirmed the award of the Zambales Workmen's Compensation Unit in favor of Consolacion F. Relente.
Ratio Decidendi
On the jurisdiction of the Commission to set aside a final and executory award: The Court held that under Rule 19, Section 1 of the Commission's Rules and Section 48 of the Workmen's Compensation Act, decisions of referees become final and executory fifteen days from receipt thereof unless appealed. In this case, the award of November 14, 1975, became final and executory on December 9, 1975, as the OSG failed to file a motion for reconsideration or petition for review within the reglementary period. Consequently, the Commission had no appellate jurisdiction to review the award. On the validity of the petition for relief from judgment: The Court found that the petition for relief from judgment was not based on any valid ground. While the OSG claimed it was filed within the period prescribed by Rule 22, Section 3, it failed to comply with the requirement of Rule 22, Section 1, which necessitates affidavits showing fraud, accident, mistake, or excusable negligence. The mere allegation of "volume and pressure of work" is not considered excusable negligence under the rules, as relief from judgment is an exceptional and equitable remedy. On the sufficiency of evidence for work-connected illness: The Court found merit in Mrs. Relente's claim, noting that Dr. Ladao's physician's report of sickness or accident dated March 14, 1975, explicitly stated that Mrs. Relente acquired her illness in "the course of her teaching profession." This report served as evidence substantiating her claim for workmen's compensation. On the validity of the controversion and waiver of defenses: The Court ruled that the respondent bureau's controversion of the claim was defective because the Assistant Solicitor General's letter merely requested the "registration" of controversion without specifying the grounds, which is contrary to Rule 10, Section 2 of the Commission's Rules. A notice of controversion that does not clearly specify the grounds is defective and does not have the effect of a valid controversion, even if filed seasonably. Due to the lack of a valid controversion, the Court concluded that the Director of Public Schools waived the defense that Mrs. Relente's illness was not compensable because it was not work-connected or work-aggravated. This waiver is consistent with established jurisprudence that failure to validly controvert a claim bars the employer from interposing such defenses.
Main Doctrine
A final and executory award under the Workmen's Compensation Act can no longer be set aside by the Commission, and a petition for relief from judgment based on mere pressure of work is not a valid ground for setting aside such an award.