GR 43744; (September, 1976) (Digest)
G.R. No. L-43744 September 30, 1976
Lapaz Q. Martinez, petitioner, vs. The Workmen’s Compensation Commission and Republic of the Philippines (Formerly Bureau of Public Schools, now Department of Education and Culture), respondents.
FACTS
Petitioner Lapaz Q. Martinez, a grade school teacher for forty-one years, filed a claim for disability compensation on August 8, 1974, due to hypertension and arthritis. After due hearing, a hearing officer of the Workmen’s Compensation Commission rendered a decision on July 16, 1975, awarding Martinez P6,000.00 in disability benefits. The respondent Republic, through the Solicitor General, received a copy of this decision-award on September 2, 1975.
The respondent failed to appeal the award within the 15-day reglementary period. Consequently, the award became final and executory on September 17, 1975. Five months later, on February 4, 1976, the respondent filed a petition for relief from judgment, alleging that its trial attorney was unable to file a motion for reconsideration due to the “usual volume and pressure of work.”
ISSUE
Whether the Workmen’s Compensation Commission retained jurisdiction to entertain a petition for relief and reverse a final and executory award.
RULING
The Supreme Court granted the petition and annulled the Commission’s decision. The Court held that the Commission no longer had any jurisdiction or authority to set aside the decision-award of July 16, 1975, as it had already become final and executory. The perfection of an appeal within the statutory period is mandatory and jurisdictional. The lapse of the appeal period renders the decision final and deprives the appellate body of jurisdiction to alter it.
Furthermore, the respondent’s petition for relief from judgment was itself filed outside the reglementary grace period prescribed for such petitions, which must be filed within 30 days from knowledge of the judgment and within 3 months from its entry. The Court emphasized that this grace period is absolutely inextendible and never interrupted. The reason proffered by the respondent—”usual volume and pressure of work”—does not constitute the mistake or excusable negligence required to warrant the exceptional remedy of relief from judgment. The basic rule on the finality of judgments, grounded on public policy and sound practice, applies indiscriminately to all parties, including the government. Accordingly, the Court reinstated the final and executory award in favor of the petitioner.