G.R. No. L-42739, L-43221, L-43406, L-43470, L-44599. January 31, 1978
Amado T. Cruz, Resurreccion Tinio, Leonor San Juan, Edward Chandler, and Alejandro Ecarma, petitioners, vs. Workmen’s Compensation Commission and Republic of the Philippines, respondents.

FACTS

These five consolidated cases involve claims for disability compensation under the Workmen’s Compensation Act. In each instance, a referee of the Workmen’s Compensation Commission rendered a decision awarding compensation and benefits to the petitioner-employee. The respondent Republic, through the Solicitor General, received copies of these awards but failed to file any motion for reconsideration or appeal within the statutory 15-day period. The reason consistently cited for the failure was the “volume and heavy pressure of work” in the Solicitor General’s office. Instead, the Republic filed petitions for relief from judgment well beyond the maximum 30-day grace period provided by law from notice of the respective decisions.
Despite the finality of the referees’ awards due to the Republic’s failure to perfect a timely appeal, the Workmen’s Compensation Commission, in each case, assumed appellate jurisdiction. It proceeded to review the merits, ultimately issuing decisions that either reversed the awards for “lack of merit” or substantially reduced the granted benefits. The petitioners thus sought review by the Supreme Court, arguing that the Commission acted without jurisdiction.

ISSUE

Whether the Workmen’s Compensation Commission had jurisdiction to review and set aside the referees’ awards after the decisions had become final and executory due to the respondent’s failure to appeal within the reglementary periods.

RULING

No. The Supreme Court set aside the Commission’s decisions and reinstated the referees’ awards in full. The Court held that the Commission lost its power of review once the referees’ decisions became final and executory. The 15-day period to appeal and the 30-day grace period for filing a petition for relief from judgment are jurisdictional and mandatory. The Court, citing Luzon Stevedoring Corporation v. Workmen’s Compensation Commission, emphasized that these periods are “absolutely fixed, inextendible, never interrupted and cannot be subjected to any condition or contingency.”
The excuse of “volume and pressure of work” offered by the respondent was deemed unacceptable and did not constitute a valid ground to toll the reglementary periods or to vest the Commission with jurisdiction it had already lost. The equitable remedy of relief from judgment is a final recourse, and failure to avail of it within the prescribed grace period is fatal. Consequently, the Commission’s act of reviewing the merits of cases with final awards was a grave abuse of discretion amounting to excess of jurisdiction. The awards, having attained finality, must be executed. The Court also increased the attorneys’ fees in three of the cases to 10% in accordance with the Act.