G.R. No. L-43425. January 22, 1980.
JULIO BISCARRA, petitioner, vs. REPUBLIC OF THE PHILIPPINES (Bureau of Forestry) and the WORKMEN’S COMPENSATION COMMISSION, respondents.

FACTS

Petitioner Julio Biscarra, a former assistant district forester, filed a claim for disability compensation due to various ailments, leading to his retirement. The Regional Office granted his claim for disability benefits and subsequently awarded him reimbursement for medical expenses in two separate orders. The second award for medical reimbursement was issued on September 24, 1975. The respondent Republic received a copy of this decision on September 30, 1975.
The Republic failed to appeal this decision within the 15-day reglementary period. Instead, on February 4, 1976, it filed a Petition for Relief from Judgment with the Workmen’s Compensation Commission, citing the “volume and pressure of work” of the trial attorney as the reason for the delay. The Commission treated this petition as an appeal and reversed the Regional Office’s award, ruling that a claimant declared totally and permanently disabled was no longer entitled to further medical expense reimbursement.

ISSUE

Whether the Workmen’s Compensation Commission acted without jurisdiction in reversing the Regional Office’s award which had already become final and executory.

RULING

Yes, the Commission acted without jurisdiction. The Supreme Court ruled that the decision of the Regional Office awarding medical reimbursement had become final and executory due to the Republic’s failure to perfect a timely appeal. The reglementary period for appeal was 15 days from receipt of the decision. The Republic received the decision on September 30, 1975, but only filed its Petition for Relief on February 4, 1976, which was 127 days later, far beyond the allowable period.
The legal logic is grounded on the doctrine of finality of judgments, a fundamental principle of public policy. The perfection of an appeal within the prescribed period is mandatory and jurisdictional. Failure to do so renders the decision final and executory, stripping appellate bodies of any authority to alter it. The Court consistently holds that the “volume and pressure of work” does not constitute excusable negligence or a valid ground for relief from judgment. Such a reason is not among the grounds provided by the rules and is insufficient to warrant an exception to the strict requirement of timeliness. Consequently, the Workmen’s Compensation Commission had no more jurisdiction to review, much less reverse, the final award. The Court reinstated the Regional Office’s decision granting the reimbursement.