GR 29540; (March, 1981) (Digest)
G.R. No. L-29540. March 27, 1981.
REPUBLIC OF THE PHILIPPINES (Bureau of Public Highways), petitioner, vs. PATROCINIO POLLOSCO and WORKMEN’S COMPENSATION COMMISSION, respondents.
FACTS
Patrocinio Pollosco, an employee of the Bureau of Public Highways, ceased work at age 63 after contracting pulmonary tuberculosis. He filed a claim for disability and medical benefits. The Acting Referee awarded him P2,101.84 as disability compensation and P5,100.00 for medical expenses. The Republic filed a motion for reconsideration only regarding the medical expenses award, not contesting the compensability or the disability amount. Pollosco moved for partial execution of the disability award, which was granted, and the petitioner was directed to pay the P2,101.84.
The entire record was elevated to the Workmen’s Compensation Commission for review. The Commission affirmed the decision but modified it, increasing the disability compensation to P4,000.00. The petitioner’s motion for reconsideration was denied by the Commission en banc.
ISSUE
Whether the Workmen’s Compensation Commission erred in modifying and increasing the disability compensation award after it had become final and executory.
RULING
Yes. The Supreme Court set aside the Commission’s decision and reinstated the Acting Referee’s award of P2,101.84. The Court ruled that the award for disability compensation had become final and executory. The petitioner did not appeal that portion of the Acting Referee’s decision; it only questioned the medical expenses award. Furthermore, Pollosco had sought and obtained an order for the execution of the disability award. The basic rule on the finality of judgments applies to awards from quasi-judicial agencies like the Commission, grounded on public policy that judgments must become final at a definite point to ensure stability. The Commission, therefore, had no authority to modify a final award.
The Court also found the Acting Referee’s computation of P2,101.84 to be correct, based on 60% of Pollosco’s average weekly wage for 104 weeks (the two years until his compulsory retirement age of 65), not exceeding the P4,000.00 statutory maximum. The Court cited its precedent in Hernandez vs. Workmen’s Compensation Commission, which holds that compensation for loss of earning capacity cannot extend beyond an employee’s compulsory retirement date. The reinstated award is separate and not deductible from any retirement gratuity Pollosco would later receive.