G.R. No. L-43134. March 26, 1979.
Carmelita E. Vega, petitioner, vs. Workmen’s Compensation Commission and Republic of the Philippines (Bureau of Public Schools), respondents.

FACTS

Petitioner Carmelita E. Vega, a public school teacher, was granted an award for disability compensation by a Hearing Referee due to an ailment that caused her disability for labor. The award, dated November 5, 1975, included compensation and reimbursement for medical expenses. The Solicitor General, representing the respondent employer, received a copy of this award on November 11, 1975, but failed to file a timely appeal within the 15-day reglementary period. Instead, on December 10, 1975, the Solicitor General filed a “Petition to Elevate the Records for Relief from Judgment,” citing “volume and heavy pressure of work” as the reason for the delay.
The respondent Workmen’s Compensation Commission, acting on this petition, proceeded to review the merits of the case. It reversed the referee’s award and dismissed Vega’s claim. The Commission ruled that her ailment, an ectopic pregnancy, was not compensable under the law and that there was insufficient proof her hypertension resulted in incapacity. Vega assailed this reversal, arguing the Commission acted without jurisdiction.

ISSUE

Whether the Workmen’s Compensation Commission acquired jurisdiction to review and reverse the Hearing Referee’s award after the period to appeal had lapsed.

RULING

No. The Supreme Court set aside the Commission’s decision and reinstated the referee’s award. The legal logic is anchored on the fundamental and mandatory nature of reglementary periods for appeal. The perfection of an appeal within the statutory period is jurisdictional. Failure to do so renders the judgment final and executory, thereby stripping the appellate body of any authority to alter it. This principle applies with equal force to quasi-judicial agencies like the Workmen’s Compensation Commission and operates against all employers, public or private.
Since the Solicitor General received notice on November 11, 1975, and did not appeal within 15 days, the award became final and executory by November 26, 1975. The subsequent petition for relief filed by the Solicitor General was insufficient to revive lapsed jurisdiction. The ground invoked—”volume and heavy pressure of work”—constitutes inexcusable negligence, not the fraud, accident, mistake, or excusable negligence required by the rules. By improvidently ruling on the merits without first conclusively resolving the improper petition for relief, the Commission committed grave abuse of discretion.
Furthermore, the Court noted that the employer had failed to effectively controvert the claim, which constitutes a waiver of non-jurisdictional defenses and an admission of compensability. The presumption of compensability, arising from the illness supervening during employment, was not rebutted by the employer. Therefore, the Commission’s decision was null and void for lack of jurisdiction, and the final and executory award in favor of Vega must stand.