G.R. No. L-43469, et al. June 30, 1976
LUZON STEVEDORING CORP., petitioner, vs. JOSE P. REYES, et al., respondents.

FACTS

Petitioner Luzon Stevedoring Corporation, a government-owned corporation, sought review of multiple orders from the Workmen’s Compensation Commission. The Commission had denied the corporation’s petitions for relief from judgments issued by a Referee in October 1975. These judgments awarded workmen’s compensation benefits to various employee-claimants. The Commission’s denial was based on the finality of the Referee’s awards, as the petitioner failed to file a timely petition for review or motion for reconsideration within the 15-day reglementary period prescribed by Section 50 of the Workmen’s Compensation Act and the Commission’s rules.
The petitioner, represented by the Office of the Solicitor General, filed petitions for relief from judgment with the Commission in early 1976. It argued that its failure to appeal was due to mistake or excusable negligence, citing the volume and pressure of work at the Solicitor General’s office. The Commission en banc rejected this, ruling it had lost appellate jurisdiction because the awards were final. The petitioner then elevated the consolidated cases to the Supreme Court, contending the Commission erred in not granting relief under Rule 38 of the Revised Rules of Court.

ISSUE

Whether the Workmen’s Compensation Commission correctly denied the petitions for relief from judgment on the ground that it had lost jurisdiction over the final and executory awards.

RULING

Yes, the Commission was correct. The Supreme Court denied all petitions. The legal logic is anchored on the doctrine of finality of judgments and the specific statutory regime governing workmen’s compensation proceedings. The petitioner’s admission that it did not appeal within the 15-day period was fatal. Upon expiration of that period, the Referee’s awards became final and executory, thereby depriving the Commission of any appellate jurisdiction to alter them. This principle was squarely applied in Ramos vs. Republic, which the Commission correctly cited.
The Court rejected the argument that Rule 38 of the Revised Rules of Court on petitions for relief should apply to extend the period. Workmen’s compensation proceedings are special statutory proceedings; the Commission’s own rules, promulgated under its quasi-judicial authority, govern. These rules provide a specific remedy and timeline. Furthermore, the petitioner failed to file its petition for relief within the Commission’s own 30-day reglementary period from notice of the award. Even assuming arguendo that Rule 38 could apply, the petitioner failed to demonstrate the required “fraud, accident, mistake, or excusable negligence” that would warrant relief. Mere pressure of work in a counsel’s office does not constitute excusable negligence. With the awards final, they constituted the law of the case, rendering moot the petitioner’s ancillary claims about lack of substantial evidence or legal basis for the awards.