G.R. No. L-44763 and L-45381. October 27, 1977.
Tomas U. Soliven, petitioner, vs. Workmen’s Compensation Commission and Republic of the Philippines (Bureau of Public Schools), respondents. / Eulogia Malijan, petitioner, vs. Republic of the Philippines (Bureau of Public Schools) and Workmen’s Compensation Commission, et al., respondents.

FACTS

These consolidated cases involve motions for reconsideration filed by the Solicitor General on behalf of the respondent Republic of the Philippines (Bureau of Public Schools). The motions seek to overturn the Court’s Decision dated June 30, 1977. The underlying dispute centers on final and executory awards granted by referees of the Workmen’s Compensation Commission (WCC) in favor of the petitioners, who were public school teachers. The respondent Republic failed to perfect an appeal from these referee decisions within the 15-day statutory period prescribed by law.
The respondent, in its motion, invoked the case of Republic vs. Workmen’s Compensation Commission (30 SCRA 811) to argue that the WCC possessed “exclusive jurisdiction” over compensation claims, implying it could review referee awards beyond the appeal period. It further contended that any judicial interpretation from an en banc decision, like the one cited, could only be modified by the Court sitting en banc, citing a constitutional provision.

ISSUE

The core issue is whether the Workmen’s Compensation Commission retained jurisdiction to alter or reverse a referee’s decision after the lapse of the 15-day statutory period for appeal, thereby rendering the award final and executory.

RULING

The Court denied the motion for reconsideration with finality. The legal logic is anchored on the fundamental principle of finality of judgments, a cornerstone of judicial and quasi-judicial proceedings. The Court clarified that the cited case of Republic vs. WCC was inapplicable as it did not abandon the statutory mandate on finality. The WCC’s “exclusive jurisdiction” is not an unbounded power; it is conditioned upon the timely perfection of an appeal. Section 50 of the Workmen’s Compensation Act explicitly provides that a decision becomes final and executory fifteen days after promulgation “unless previously appealed.”
The respondent’s failure to appeal within this mandatory and jurisdictional period rendered the referees’ awards final. Consequently, the WCC was divested of any authority to alter them. Execution of such final awards becomes a ministerial duty. The Court also rejected the tenuous argument regarding petitions for relief from judgment, emphasizing that the 30-day grace period for such an equitable remedy is “absolutely fixed, inextendible, never interrupted.” Even within this period, relief is granted only upon a clear showing of fraud, accident, mistake, or excusable negligence, which was not demonstrated here. The doctrine of finality is indispensable for the orderly and speedy discharge of business, especially in workmen’s compensation cases designed for the expeditious delivery of benefits to needy workers and their families.