G.R. No. L-43112 and G.R. No. L-43307, May 31, 1977
Pedro Carreon vs. Workmen’s Compensation Commission and Republic of the Philippines (Bureau of Posts); Bienvenido Regala vs. Workmen’s Compensation Commission and Republic of the Philippines (Bureau of Agricultural Extension)

FACTS

In G.R. No. L-43112, the Workmen’s Compensation Commission (WCC) referee awarded Pedro Carreon disability compensation for his arteriosclerotic heart disease, aggravated by his long employment as a mail carrier. The decision was received by the respondent Republic, through the Solicitor General, on September 4, 1974. The Republic filed a motion to set aside the award only on September 24, 1974, which was five days beyond the 15-day reglementary appeal period. The referee correctly denied the motion, declaring the award final and executory. Nevertheless, the WCC later ordered the elevation of the records and subsequently issued a decision dismissing Carreon’s claim.
In G.R. No. L-43307, the WCC referee awarded Bienvenido Regala disability compensation for PTB and a bleeding ulcer incurred during his strenuous work as a laborer. The Republic received notice of this decision on November 3, 1975. It filed a “Motion to Elevate Records” only on December 15, 1975, which was 27 days beyond the 15-day appeal period. Despite this lapse and the absence of a timely petition for relief, the WCC still elevated the records and later issued a decision dismissing Regala’s claim.

ISSUE

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

RULING

No. The Supreme Court annulled the WCC’s decisions and reinstated the referees’ awards. The Court held that the perfection of an appeal within the reglementary period is both mandatory and jurisdictional. The Republic’s failure to appeal the referees’ decisions within the 15-day period prescribed by law rendered those awards final and executory. Consequently, the WCC was divested of any authority to alter, review, or set aside the final judgments. The Court reiterated the fundamental policy on the finality of judgments, which applies indiscriminately to all parties, including the government, to ensure stability in judicial and quasi-judicial determinations. The only recognized exception is a timely petition for relief from judgment, which was not filed in these cases. Therefore, the WCC acted without jurisdiction when it entertained the belated motions and proceeded to dismiss the claims. The awards were reinstated, with the modification that attorney’s fees were increased due to the services rendered in the Supreme Court appeal.