GR 43212; (July, 1977) (Digest)
G.R. No. L-43212. July 27, 1977.
ANTONIO PEPITO, for himself and in behalf of his daughter, GIRLIE C. PEPITO, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and REPUBLIC OF THE PHILIPPINES (Bureau of Public Schools), respondents.
FACTS
The late Maxima Pepito was a classroom teacher from September 23, 1970, until her death on September 30, 1974. After her first two years of service, she began experiencing dizziness. In 1973, she complained about her eyesight and began using eyeglasses. Following the school year, she went on sick leave starting June 4, 1973. After giving birth in June 1973, she suffered severe headaches and high blood pressure, was diagnosed with a cerebro-vascular accident, and became blind six months later. She was eventually admitted to a hospital in September 1974, where she was diagnosed with a brain tumor and died the following day. Her husband filed a claim for death benefits.
The Workmen’s Compensation Unit awarded benefits, but the respondent Commission reversed this decision. The Commission reasoned that the teacher’s illness manifested and progressed during the long summer vacation when she was not actively working, thus breaking any causal connection to her employment. It also noted the long period between her leave and her death. The Solicitor General’s petition for relief from the Unit’s award was filed 96 days after receipt, far beyond the 15-day reglementary period.
ISSUE
The primary issues were: (1) whether the illness and death of Maxima Pepito arose out of or in the course of her employment, and (2) whether the Workmen’s Compensation Commission validly acquired jurisdiction to review the award given the late filing of the petition for relief.
RULING
The Supreme Court reversed the Commission’s decision and reinstated the award. On the first issue, the Court held that the presumption of compensability under the Workmen’s Compensation Act applied. The deceased’s symptoms of dizziness and deteriorating eyesight emerged during her employment and were logically early symptoms of the brain tumor that caused her death. The Court emphasized that the employer-employee relationship persisted during the summer vacation, and the illness’s manifestation during this period did not sever its connection to her work as a teacher. The Commission’s finding of no causal relation was baseless.
On the jurisdictional issue, the Court ruled that the Commission lost jurisdiction to review the case. The Solicitor General’s petition for relief was filed 96 days after notice of the award, blatantly exceeding the 15-day period for finality. Pressure of work is not a valid ground for relief from judgment. Consequently, the award had become final and executory, and the Commission’s decision reversing it was void. The Court underscored that workmen’s compensation claims are imbued with public interest under the social justice guarantee, requiring prompt resolution for the benefit of workers and their heirs. The respondent Bureau of Public Schools was ordered to pay death benefits, medical and burial expenses, and administrative fees.
