Adm. Case No. 482 - Cruz vs. Cabal

Rosario Cruz is the complainant who filed a claim for compensation relating to the death of her husband, Juanito Guinto, employed by the Royal Theater.
Respondents, Atty. Edmundo T. Cabal and Atty. Manuel A. Calupitan, are officers of the Legal Division of the Regional Office of the Department of Labor and are charged with gross negligence in the performance of their duties as alleged by the Solicitor General.

On April 14, 1958, Rosario Cruz filed a compensation claim (W.C. Case No. RO3-53285) with the Regional Office (formerly No. 3) of the Department of Labor.
The claim was based on the employer’s failure to report the death of her husband, prompting Hearing Officer Vicente Leonardo, Jr. to issue an administrative award on August 21, 1958, directing the Royal Theater to pay P4,200.00.

Before execution of the administrative award, the Royal Theater filed a complaint for prohibition with a preliminary injunction on September 29, 1958, in the Court of First Instance of Manila, challenging the jurisdiction of the Regional Office to hear the claim.
On September 30, 1958, Judge Bienvenido A. Tan issued a writ of preliminary injunction ex parte, ordering the defendants to file their answer within ten days.
The Regional Administrator, F. A. Fuentes, referred the case to respondent Calupitan for representation at the trial court, and Calupitan subsequently assigned the matter to respondent Cabal.

Atty. Cabal filed the answer on October 9, 1958, defending the constitutionality of Reorganization Plan No. 20-A and relevant legislative provisions, while attacking the complaint.
After trial, the Court of First Instance of Manila ruled that the Workmen’s Compensation Unit of Regional Office No. 3 lacked the authority to try the claim, and it made the provisional injunction permanent.
The decision was personally received by respondent Calupitan on January 9, 1959.

Respondent Calupitan delivered the decision to respondent Cabal, who, due to negligence or inadvertence, misplaced the decision by attaching it to another case’s records.
The decision was not located until February 12, 1959, which was 19 days after the reglementary period for filing an appeal had expired under Section 17, Rule 21 of the Rules of Court.
Consequently, respondent Cabal filed a motion for an extension of at least 10 days to perfect the necessary appeal, citing the misplacement of the decision and the constitutional issue raised regarding Reorganization Plan No. 20-A.

The trial court, finding merit in the motion, issued an order on February 14, 1959, extending the period for appeal.
Despite the extension, procedural irregularities continued, including the late payment of the docketing fee:

On March 12, 1959, the Supreme Court notified respondent Cabal to pay the docketing fee.
On March 17, 1959, respondents attempted to confer with Rosario Cruz regarding the payment; however, Cruz was ultimately unable to effect the timely payment.
Rosario Cruz’s attempt to pay on April 1, 1959, was rejected by the Supreme Court for being one day late.

A petition for the admission of the docketing fee was filed by respondents but was denied by the Supreme Court.
A motion for reconsideration was subsequently filed, only to be denied.

Rosario Cruz wrote a letter on January 30, 1961, blaming respondents for the dismissal of her appeal.
The Solicitor General concluded:

The dismissal of the appeal was primarily due to the failure of Rosario Cruz to pay the docket fees promptly.
Nonetheless, the motion for reconsideration, filed 19 days late due to the misplacement of the decision by respondent Cabal—and the delayed filing by respondent Calupitan—was ultimately untimely despite efforts to secure an extension.
While there is an exception under Rule 38 for petitions for relief, the motion in question failed to meet all procedural requirements, such as verification and an affidavit of merits.

The Solicitor General also noted that the constitutional issue regarding the validity of Reorganization Plan No. 20-A, which expanded the adjudicatory powers of the regional offices, was a matter of law. This issue was later upheld in subsequent decisions by the Supreme Court.
It was emphasized that the respondents’ negligence was tied to their official duties; their relationship with Rosario Cruz was not Attorney–client but that of official representatives of the Department of Labor.

Considering the nature of the errors arising out of official mishandling—rather than personal breach of attorney-client duties—the court determined that disciplinary action against the respondents was not warranted.
Accordingly, the complaint against respondents Atty. Edmundo Cabal and Atty. Manuel Calupitan was dismissed.

Whether the extension of the appeal period granted by the trial court could be used to cure the lapse resulting from the misplacement of the decision.
Whether the subsequent late payment of the docketing fee constituted a sufficient ground for the dismissal of the appeal.

Whether the negligence in handling the case—specifically, the misplacement of the decision and late filing of the motion for reconsideration—amounted to gross negligence in the performance of their duties.
Whether such administrative negligence, being part of their official duties as officers of the Legal Division, could subject them to discipline as lawyers.

Whether the Workmen’s Compensation Unit of Regional Office No. 3 had the jurisdiction to entertain the claim filed by Rosario Cruz.
The constitutionality of Reorganization Plan No. 20-A, notably as it pertains to granting judicial powers to regional offices in adjudicating workers’ compensation claims.