G.R. No. L-43539 August 31, 1978
ODON CRUZ CUETO, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION AND THE REPUBLIC OF THE PHILIPPINES (BOARD OF LIQUIDATORS), respondents.

FACTS

Odon Cruz Cueto, employed by the Board of Liquidators since 1951, was compelled to retire on March 27, 1974, due to a cerebral stroke that rendered him totally and permanently disabled. He filed a compensation claim, which was granted by Acting Referee Ignacio V. Valera on April 14, 1975. The decision awarded him the maximum disability compensation of P6,000, reimbursement for medical expenses amounting to P12,071.13, and an attorney’s fee.
The Office of the Solicitor General, representing the employer, filed a motion for reconsideration. This motion specifically contested only the award for medical expenses, arguing that the receipts had not been submitted to the Compensation Medical Rating Officer for evaluation. The motion explicitly prayed for reconsideration “insofar as reimbursement of medical expenses is concerned” and requested that the claim for these expenses be denied unless properly evaluated. The referee granted this partial reconsideration, and on October 30, 1975, issued a new award reducing the reimbursable medical expenses to P3,098.02.

ISSUE

Whether the Workmen’s Compensation Commission acted with jurisdiction in modifying the referee’s final award for disability compensation when the employer’s motion for reconsideration contested only the award for medical expenses.

RULING

The Supreme Court ruled that the Commission acted without jurisdiction. The legal logic is grounded in the doctrine of finality of judgments and the scope of a motion for reconsideration. The referee’s decision of April 14, 1975, became final and executory as to the disability compensation award because the employer’s subsequent motion for reconsideration, filed by Assistant Solicitor General Hector Fule, was explicitly limited. It only sought reconsideration of the portion concerning medical expenses. By not contesting the disability award, the employer impliedly accepted it, allowing it to attain finality.
Consequently, when the case was elevated to the Commission, its review authority was confined only to the aspect of medical expenses, which was the sole subject of the timely motion. The Commission exceeded its jurisdiction by reopening and reducing the already-final disability compensation award. The employer’s later “Motion to Set Aside Decision,” which attempted to challenge jurisdiction over the entire case, was deemed a mere scrap of paper as the employer had already participated in the proceedings. Therefore, the Supreme Court reinstated the referee’s awards: P6,000 as disability compensation and P3,098.02 for medical expenses.