Daza v. Republic of the Philippines
REITERATIONFacts
1. The Antecedents: Benedicta C. Daza, a public school teacher from October 11, 1937, to June 2, 1974, filed a claim for sickness compensation. She alleged contracting serious ailments, including arteriosclerotic heart disease and myocardial ischemia, in the course of her employment and that these conditions forced her to stop working on June 2, 1974. She further claimed to have notified her superior of her ailments in June 1974. 2. Procedural History: The Workmen's Compensation Commission's Regional Office No. 9 initially ruled in favor of petitioner Daza, ordering the respondent Republic of the Philippines (Bureau of Public Schools) to pay compensation benefits and medical expenses. However, upon appeal, the respondent Workmen's Compensation Commission (WCC) reversed this decision, dismissing Daza's claim. The WCC found that Daza's retirement on June 2, 1974, at age 60, was optional and not due to disability, that her service records indicated continuous work without absence, and that her physician reported disability for only two months, with no employer-employee relationship existing after her retirement. 3. The Petition: Petitioner Benedicta C. Daza sought review of the WCC's decision before the Supreme Court, raising four grounds. These included allegations that the WCC erred in giving due course to a petition for relief from judgment that was filed out of time and lacked proper grounds, and that the WCC erred in dismissing her claim on its merits. She also challenged the WCC's promulgation of rules that extended the finality of decisions as ultra vires. The Supreme Court, however, found the petition for relief from judgment to be timely filed and substantially compliant, affirmed the WCC's factual findings as supported by evidence, and upheld the validity of the WCC's promulgated rules.
Issue(s)
Whether the petition to elevate records for relief from judgment was filed out of time. Whether the petition to elevate records for relief from judgment stated any valid ground. Whether the respondent Commission erred in dismissing the claim for lack of merit. Whether the respondent Commission erred in giving due course to the petition to elevate records for relief from judgment pursuant to its Rules, which petitioner claims are ultra vires.
Ruling
The petition is dismissed for lack of merit. The decision of the Workmen's Compensation Commission is affirmed.
Ratio Decidendi
On the timeliness of the petition to elevate records: The Court found that the petition filed by the Solicitor General was within the reglementary period. The decision was received by the Office of the Solicitor General on October 28, 1975, and the petition was filed by registered mail on November 21, 1975, which is 24 days after receipt, thus falling within the allowable period. On the grounds for the petition to elevate records: The Court held that the Solicitor General's petition was meritorious and constituted substantial compliance with the rules. The ground relied upon was stated in the affidavit of merit, which cited the great volume of work requiring similar preferential attention as the reason for the delayed filing of the motion for reconsideration. The Court acknowledged the tremendous workload of the Solicitor General's office. On the dismissal of the claim for lack of merit: The Court found that the denial of the petitioner's claim was based on findings of fact by the Commission that were duly supported by the evidence on record. The Court reiterated the principle that findings of the Commission, if supported by substantial evidence, are conclusive and binding. Furthermore, the petitioner failed to sufficiently show that her illness disabled her from work. The Court emphasized that as long as an employee is able to work and receives her pay, even when suffering from illness, she is not entitled to compensation because only injuries affecting earning power are compensated, citing Lombo vs. Standard Cigarette Manufacturing Co.. On the validity of the Commission's Rules: The Court disagreed with the petitioner's argument that the Commission's rules were ultra vires. The Court stated that these rules were promulgated pursuant to the authority vested in the Commission by Section 7-A of the Workmen's Compensation Act, as amended. The Court cited Victorias Milling Co., Inc. vs. Social Security Commission, explaining that when an administrative agency promulgates rules and regulations, it "makes" a new law with the force and effect of a valid law, as statutes are often couched in general terms, leaving the details to the administrative agency entrusted with enforcement.
Main Doctrine
An employee is not entitled to compensation for illness if the illness did not disable her from work and she continued to receive her salary, especially when the retirement was optional and not based on disability.