GR 45618; (February, 1990) (Digest)
G.R. No. 45618 February 15, 1990
MARIA C. ROLDAN, petitioner, vs. REPUBLIC OF THE PHILIPPINES (BUREAU OF PUBLIC SCHOOLS), AND THE WORKMEN’S COMPENSATION COMMISSION and/or THE SECRETARY OF LABOR, respondents.
FACTS
Maria C. Roldan, a public school teacher and later head teacher from 1938 to 1971, filed a claim for disability compensation under Act No. 3428, as amended. She alleged that her ailments of hypertension and weak heart were contracted and aggravated by the stresses of her teaching and supervisory duties, which included long hours of lesson preparation, student consultations, and administrative work. Her physician confirmed the work-related nature and aggravation of her conditions, which forced her to retire at age 56. The Assistant Chief and Acting Referee of the Workmen’s Compensation Commission (WCC) awarded her compensation in a decision dated August 7, 1975.
The Office of the Solicitor General, representing the respondent, received a copy of this award on September 25, 1975. However, it filed a petition for relief from judgment with the WCC only on February 4, 1976, well beyond the 15-day reglementary period for appeal prescribed by the WCC Rules. Despite this tardiness, the WCC en banc acted on the petition and, on February 12, 1976, reversed the referee’s decision and dismissed Roldan’s claim. Roldan filed the instant petition, arguing the WCC exceeded its jurisdiction by reviewing a final and executory decision.
ISSUE
Whether the Workmen’s Compensation Commission acted without jurisdiction or with grave abuse of discretion in reviewing and reversing the final and executory decision of its Assistant Chief and Acting Referee.
RULING
Yes. The Supreme Court granted the petition, reinstated the referee’s award, and declared it final and executory. The Court emphasized the mandatory and jurisdictional nature of the 15-day period for appealing a referee’s decision to the Commission, as provided under Section 1, Rule 19 of the WCC Rules. Since the Solicitor General filed the petition for relief 132 days after receiving the referee’s decision, the judgment had long become final and unappealable. A decision that has attained finality becomes immutable and unalterable; it can no longer be modified, much less reversed, by any court or tribunal, including the issuing agency itself. This doctrine of finality of judgment is a fundamental principle intended to end litigation.
Consequently, the WCC en banc had no more jurisdiction to entertain the belated petition or to re-examine the merits of the case. Its act of doing so constituted a grave abuse of discretion amounting to lack of jurisdiction. The Court further upheld the factual findings of the referee, which were supported by evidence and established that Roldan’s ailments were work-related and compensable. The respondent’s failure to timely controvert the claim or present contrary evidence resulted in a waiver of its defenses. The Court thus ordered the immediate execution of the original compensation award in favor of the petitioner.