Title
Cruz vs. Workmen's Compensation Commission
Case
G.R. No. L-42739
Decision Date
Jan 31, 1978
The Supreme Court reinstates referees' awards for claimants, highlighting the mandatory nature of timely appeals and the finality of decisions in workmen's compensation cases.
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Case Digest (G.R. No. L-42739)

Facts:

  • Five separate petitions were filed by Amado T. Cruz, Resurreccion Tinio, Leonor San Juan, Edward Chandler, and Alejandro Ecarma against the Workmen's Compensation Commission and the Republic of the Philippines.
  • The Supreme Court rendered decisions on January 31, 1978.
  • Each petitioner had received awards for disability compensation due to work-related ailments.
  • In G.R. No. L-42739, Amado T. Cruz was awarded P5,796.28 for acute rheumatism and hypertension, developed during his employment from January 10, 1928, to October 31, 1972.
  • The respondent failed to appeal within the 15-day statutory period, citing a heavy workload, and filed a belated petition for relief on January 6, 1976.
  • In G.R. No. L-43221, Resurreccion Tinio received P4,438.19 for malignant hypertension after teaching from 1947 to 1975, with a late appeal filed on January 16, 1976.
  • In G.R. No. L-43406, Leonor San Juan was awarded P2,684.40 for pulmonary tuberculosis and cerebro-vascular thrombosis, with a late appeal filed on February 10, 1976.
  • In G.R. No. L-43470, Edward Chandler received P11,653.88 for medical expenses related to pulmonary tuberculosis, with a late petition for relief filed on March 4, 1976.
  • In G.R. No. L-44599, Alejandro Ecarma was granted P6,000.00 for permanent disability due to Parkinson's Disease, with a late appeal filed on November 27, 1975.
  • The Workmen's Compensation Commission reversed the referees' awards, claiming a lack of merit, despite the awards being final and executory.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of the petitioners, reinstating the referees' awards of disability compensation and benefits.
  • The Court held that the Commission lacked the authority to alter final judgments or awards that had become final due to the lapse of s...(Unlock)

Ratio:

  • The decision was based on the principle of finality of judgments, a fundamental aspect of judicial proceedings.
  • The Court emphasized that statutory periods for appeal and petitions for relief are jurisdictional, not merely procedural.
  • The respondent's failure to file a...continue reading

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