GR 43709; (September, 1976) (Digest)
G.R. No. L-43709 September 30, 1976
MARY J. RANADA, ET AL. vs. WORKMEN’S COMPENSATION COMMISSION AND REPUBLIC OF THE PHILIPPINES (SUPREME COURT)
FACTS
Judge Santiago Ranada Sr. died due to stress gastric bleeding. His heirs, the petitioners, filed a claim for death benefits under the Workmen’s Compensation Act against his employer, the Republic (Supreme Court). The respondent did not controvert the claim. The Acting Labor Referee, after hearing, awarded compensation and reimbursement for medical expenses. The Office of the Solicitor General received a copy of this decision on November 17, 1975.
On December 11, 1975, twenty-four days after receipt, the respondent filed a “Petition To Elevate Records” to the Workmen’s Compensation Commission. The petitioners objected, arguing the decision had become final. Despite this, the Commission motu proprio modified the award, reducing the amount for medical reimbursement. The petitioners now seek review, arguing the Commission acted without jurisdiction.
ISSUE
Whether the respondent Workmen’s Compensation Commission acted within its jurisdiction in taking cognizance of and deciding the appeal filed by the respondent Republic beyond the reglementary period.
RULING
The Supreme Court ruled that the Commission acted without jurisdiction. The legal logic is anchored on the finality of judgments and strict compliance with procedural periods. Section 49 of the Workmen’s Compensation Act mandates that a petition for review of a referee’s decision must be filed within fifteen days from notice. The respondent received notice on November 17, 1975, but filed its petition only on December 11, 1975, which was nine days late. Consequently, the Acting Labor Referee’s decision had already become final and executory.
The respondent’s argument that its petition was equivalent to a petition for relief from judgment under the Rules of Court was rejected. The Court held that a petition for relief is a separate remedy with its own requisites, including a showing of fraud, accident, mistake, or excusable negligence. The respondent’s mere allegation of “extreme pressure of work” did not constitute the excusable negligence required by law. Since the reglementary period for appeal had lapsed, the Commission was divested of any appellate jurisdiction to alter the final award. The Court reinstated the original decision of the Acting Labor Referee.