GR 43691; (September, 1978) (Digest)
G.R. No. L-43691 September 30, 1978
FELICISIMO LIGASON, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and REPUBLIC OF THE PHILIPPINES (Bureau of Public Schools), respondents.
FACTS
Felicisimo Ligason, a public school principal, filed a claim for disability compensation due to illnesses (nephritis and hyperacidity) allegedly contracted and aggravated in the course of his employment. The Hearing Officer of the Workmen’s Compensation Unit awarded him compensation and medical reimbursement. The Office of the Solicitor General, representing the Bureau of Public Schools, received a copy of this award on October 20, 1975. No motion for reconsideration or appeal was filed within the 15-day reglementary period.
Instead, after the lapse of this period, the claimant moved for execution, which was granted. Only then, on November 12, 1975, did the Solicitor General file a petition to elevate records for relief from judgment, citing heavy workload as the reason for the delay. The Workmen’s Compensation Commission subsequently reversed the Hearing Officer’s award and absolved the government of liability. Ligason petitioned the Supreme Court, arguing the initial award had become final and executory due to the respondent’s failure to timely appeal.
ISSUE
Whether the Workmen’s Compensation Commission had jurisdiction to review and reverse the Hearing Officer’s decision after the reglementary period for appeal had lapsed.
RULING
The Supreme Court ruled in favor of the petitioner, Ligason, and set aside the Commission’s decision. The Court reinstated the Hearing Officer’s award. The legal logic is anchored on the finality of judgments and jurisdictional limits. Under Section 49 of the Workmen’s Compensation Act, a party has fifteen (15) days from receipt of a referee’s decision to seek reconsideration or review by the Commission.
The Solicitor General’s admission of receipt on October 20, 1975, and the filing of the petition only on November 12, 1975, clearly placed the action beyond the reglementary period. The Court, citing precedent in Ranada vs. Workmen’s Compensation Commission, held that the expiration of this period rendered the Hearing Officer’s decision final and executory. Consequently, the Commission was divested of any appellate jurisdiction to entertain the late petition or to reverse the award.
The respondent’s argument that the petition was a valid petition for relief from judgment was rejected. The alleged “pressure of work” of a trial attorney does not constitute the fraud, accident, mistake, or excusable negligence required to grant such relief. The Court emphasized the mandatory nature of procedural timelines, which apply equally to the government. Having lost its right to appeal, the government was bound by the final award. On the merits, the Court also noted the Physician’s Report substantiated that the illnesses were work-related and compensable.