Delgado v. Republic of the Philippines
REITERATIONFacts
1. The Antecedents: Lourdes Delgado, a public school teacher, became disabled for work on June 3, 1969, due to a diagnosed eye ailment of cataract. She underwent surgery for this condition. She subsequently filed a claim for compensation. 2. Procedural History: Delgado filed her compensation claim on July 29, 1974. The Bureau of Public Schools, represented by the Office of the Solicitor General, contested the claim. On September 22, 1975, an Acting Referee ruled in favor of Delgado, awarding disability benefits and reimbursement for medical expenses. The respondent filed a Motion to Elevate Records for Relief of Judgment on November 14, 1975, alleging an overloaded schedule prevented timely action. On January 16, 1976, the Workmen's Compensation Commission reversed the referee's decision, deeming cataract non-compensable and not work-related. 3. The Petition: Delgado filed a petition for review on January 7, 1977, arguing the Commission's decision was void for lack of jurisdiction, as the respondent's motion for relief was filed beyond the reglementary period. She also contended that the Commission erred in dismissing her claim, asserting that the respondent failed to rebut the presumption of compensability and that her cataract was aggravated by her work, citing evidence of her prior physical fitness and the physician's report attributing the condition to work strain. The Supreme Court considered whether the respondent's motion for relief was timely and whether the cataract was a compensable illness.
Issue(s)
Whether the Workmen's Compensation Commission had jurisdiction to review the referee's decision when the motion for relief from judgment was filed beyond the reglementary period. Whether the petitioner's cataract condition is a compensable illness under the Workmen's Compensation Act.
Ruling
The petition for review is GRANTED. The decision of the Workmen's Compensation Commission dated January 16, 1976, is REVERSED and SET ASIDE, and the award of the Acting Referee dated September 22, 1975, is REINSTATED and AFFIRMED.
Ratio Decidendi
On the issue of jurisdiction: The Court held that the Workmen's Compensation Commission had no jurisdiction to review the referee's decision. The referee's decision was rendered on September 22, 1975, and the respondent received a copy on September 25, 1975. The Motion to Elevate Records for Relief from Judgment was filed only on November 11, 1975, which was clearly beyond the reglementary period provided by law. According to Section 49 and 50 of Act 3428, as amended, a decision becomes final and executory fifteen (15) days after its promulgation unless appealed within the prescribed period. Since the motion was filed late, the referee's decision had already become final and executory. Consequently, the WCC had no more jurisdiction to review the same, and its judgment reversing the referee's award was void for having been rendered without jurisdiction. The Court emphasized that statutory periods for appeals and petitions for relief from judgment are not merely matters of form but of substance, dealing with the very jurisdiction of the commission, citing Cruz v. Workmen's Compensation Commission. On the issue of compensability: The Court found merit in the petitioner's claim for compensation. Under Act 3428, as amended, there is a disputable presumption that a sickness contracted during employment either arose out of or was aggravated by the nature of the work, shifting the burden to the employer to overthrow this presumption. The evidence showed that petitioner was physically fit in 1938 and contracted cataract in 1969, requiring an operation. The "Physician's Report of Sickness or Accident" indicated "Due to strain and pressure of work" as the cause and affirmed that the illness was caused by and aggravated by the employment. The respondent Republic merely averred that cataract is a result of the aging process and not an occupational disease, but presented no other evidence to substantiate this claim. The Court noted that cataract is not caused exclusively by aging and that respondent failed to show that petitioner's cataract was of a non-compensable type. Relying on Matta v. Workmen's Compensation Commission and Bautista v. Workmen's Compensation Commission, the Court stated that advancing age alone is not sufficient to remove an ailment from the periphery of compensable disabling diseases, especially when constant physical and mental exertions, strain, and tension are contributing and aggravating factors. The Court distinguished this case from Zozobrado v. Employees' Compensation Commission, which involved senile cataract under new rules that removed the presumption of compensability.
Main Doctrine
The Workmen's Compensation Commission loses jurisdiction to review a referee's decision if a motion for reconsideration or appeal is filed beyond the reglementary period, rendering the referee's decision final and executory. Furthermore, the presumption of compensability for sicknesses arising in the course of employment shifts the burden to the employer to prove otherwise, and a bare allegation of aging as the cause of a condition like cataract is insufficient to rebut this presumption without substantial evidence.