Integrated Construction Services, Inc. v. Workmen's Compensation Commission
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a claim for death benefits under the Workmen's Compensation Act (WCA). Juana Ramora Vda. de Corpuz filed a claim for the death of her son, Orlando Corpuz, who was employed by Integrated Construction Services, Inc. and Engineering Construction, Inc. The claim was initially dismissed by a hearing officer. 2. Procedural History: The private respondent appealed the hearing officer's decision to the Workmen's Compensation Commission (Commission). An Associate Commissioner reversed the hearing officer's decision and awarded death benefits. The petitioners then filed a motion for reconsideration with the Commission en banc. The Commission en banc denied this motion, ruling that it was filed beyond the reglementary period. 3. The Petition: This petition for certiorari, mandamus, and prohibition seeks to annul the Commission's order denying the motion for reconsideration. The petitioners argue that their motion was timely filed under Section 49 of the WCA, which they interpret as providing a 15-day period for appeals from an Associate Commissioner's decision to the Commission en banc. They contend that Section 49, being a substantive provision, should prevail over Section 1, Rule 17 of the Commission's Rules, which prescribes a 10-day period.
Issue(s)
Whether Section 1, Rule 17 of the Rules of the Commission or Section 49 of the Workmen's Compensation Act governs the reglementary period for filing a motion for reconsideration of an Associate Commissioner's decision to the Commission en banc. Whether the petitioners' motion for reconsideration was filed within the reglementary period.
Ruling
The petition is dismissed. The order of the Commission en banc dated September 11, 1970, affirming the dismissal of the petitioners' motion for reconsideration, is affirmed. Petitioners are ordered to pay the private respondent the amounts awarded in the decision dated July 23, 1970. The decision is immediately executory, and no motion for extension of time to file a motion for reconsideration will be allowed.
Ratio Decidendi
On the governing reglementary period: The Court held that Section 1, Rule 17 of the Rules of the Commission, which prescribes a ten (10) day period for filing a motion for reconsideration of a member's decision to the Commission en banc, is the applicable rule. This is consistent with the Commission's authority to promulgate rules for its internal functions, including appeals from individual members to the Commission en banc, as granted by Section 7-A of the WCA as amended by Republic Act No. 4119. The Court clarified that Section 49 of the WCA, which provides a fifteen (15) day period, refers to appeals from the Commission en banc to the Supreme Court, not to intra-Commission appeals. This interpretation aligns with established jurisprudence in Davao Gulf Lumber Corp. v. Hon. Del Rosario, et al. and Manila Trading and Supply Co. v. Workmen's Compensation Commission. On the timeliness of the motion for reconsideration: The petitioners received the Associate Commissioner's decision on August 7, 1970. Under the ten (10) day reglementary period provided by Section 1, Rule 17 of the Commission's Rules, their motion for reconsideration should have been filed by August 17, 1970. Since the motion was filed on August 22, 1970, it was filed out of time. Consequently, the decision of the Associate Commissioner had become final and executory, and the Commission en banc correctly lost jurisdiction to review the motion. The Court found no abuse of discretion on the part of the Commission en banc in dismissing the motion on this ground.
Main Doctrine
The ten (10) day period prescribed under Section 1, Rule 17 of the Rules of the Workmen's Compensation Commission governs the filing of a motion for reconsideration of the decision of an Associate Commissioner to the Commission en banc, and not the fifteen (15) day period under Section 49 of the Workmen's Compensation Act, as the latter provision refers to appeals from the Commission en banc to the Supreme Court.