Case Digest (G.R. No. 78164)
Facts:
The case revolves around Lourdes Delgado, a public school teacher employed by the Bureau of Public Schools in the Philippines. On June 3, 1969, she became disabled due to a medical condition identified as a "cataract, mature, right and incipient, left." To address her ailment, she underwent an operation at Our Lady of Lourdes Hospital. Subsequently, on July 29, 1974, she filed a claim for compensation due to her disability. The Office of the Solicitor General, which represented the Bureau of Public Schools, contested the claim on August 15, 1974. On September 22, 1975, Acting Referee Benjamin Perez issued a favorable decision for Delgado, ordering her employer to pay her P3,283.75 in disability benefits, P766.63 for medical expense reimbursements, and P164.18 in attorney's fees.
Despite receiving the decision on September 25, 1975, the Department of Education and Culture, through the Solicitor General, filed a Motion to Elevate Records for Relief from Judgment on
Case Digest (G.R. No. 78164)
Facts:
- Background of the Case
- Petitioner Lourdes Delgado, a public school teacher, was employed by the Bureau of Public Schools.
- In the course of her employment, she was diagnosed with an eye ailment characterized as "cataract, mature, right and incipient, left" and was rendered disabled for work from June 3, 1969.
- She underwent an operation at Our Lady of Lourdes Hospital for her ailment.
- Filing of the Claim and Initial Award
- On July 29, 1974, Delgado filed her claim for workmen’s compensation benefits.
- The Bureau’s Office of the Solicitor General, representing the employer, controverted her claim on August 15, 1974.
- Acting Referee Benjamin Perez of the Workmen’s Compensation Section, Regional Office No. 4, rendered a decision on September 22, 1975 awarding:
- Disability benefits amounting to P3,283.75,
- Reimbursement of medical expenses of P766.63 (pursuant to Section 13 of the Act),
- Attorney’s fees of P164.18, and
- Direct payment to the Office of P33.00.
- The decision was received by the Office of the Solicitor General on September 25, 1975.
- Intervention by the Respondents and Motion to Elevate Records
- On November 14, 1975, the respondent, Department of Education and Culture, through the Office of the Solicitor General, filed a Motion to Elevate Records for Relief from Judgment.
- The motion alleged that due to the heavy schedule of hearings and extensive written work, including preparations for briefs and pleadings in various courts and administrative agencies, the filing of a Motion for Reconsideration was delayed.
- It also contended that the referee erred in awarding benefits under Sections 14 and 15 of the Workmen’s Compensation Act, as amended.
- On January 7, 1976, Associate Commissioner Dioscora C. Arellano, with the concurrence of Chairman Severo M. Pucan, gave due course to the motion.
- Subsequently, on January 16, 1976, the Workmen’s Compensation Commission rendered a two-page decision reversing the referee’s award on the following basis:
- Previous cases had held that cataract is not a compensable ailment because it is generally a natural consequence of aging.
- The petitioner, who was 53 years old at the time of the operation, was deemed to have developed cataract as a result of natural degeneration rather than from the strain and pressures of her employment.
- Consequently, the petitioner was denied not only the disability benefits but also the reimbursement of medical expenses.
- Petition for Review by the Petitioner
- On January 7, 1977, Delgado filed a petition for review challenging the Commission’s decision, arguing that:
- The decision of the Workmen’s Compensation Commission was rendered without jurisdiction since the Motion to Elevate Records was filed beyond the reglementary period.
- There was a procedural defect regarding the receipt of the Commission’s decision, as evidence showed that the petitioner was not furnished a copy until January 3, 1977.
- The respondent, for its part, argued that the petition was filed beyond the ten-day reglementary period as provided under Rule 18, Section 1 of the Rules of the Workmen’s Compensation Commission and Rule 43, Section 4 of the Rules of Court.
- The record showed discrepancies in the alleged receipt dates, with official registry documents indicating the decision was received by the Solicitor General on January 27, 1976—not by the petitioner.
- These facts underpinned the petitioner’s argument that her delay in filing the petition for review was not attributable to her negligence.
Issues:
- Timeliness and Procedural Lapses
- Whether the petition for review was filed beyond the prescribed reglementary period mandated by the Rules of the Workmen’s Compensation Commission and affirmed by the Rules of Court.
- Whether the petitioner was prejudiced by not receiving a copy of the Commission’s decision in a timely manner.
- Jurisdictional Authority of the Workmen’s Compensation Commission
- Whether the Commission had the jurisdiction to review and reverse the referee’s award once the statutory appeal period had lapsed.
- Whether the Motion to Elevate Records for Relief from Judgment, filed beyond the mandatory period, deprived the Commission of jurisdiction to alter the referee’s decision.
- Compensability of the Ailment
- Whether the cataract, which the petitioner contracted and for which she underwent operation, should be considered a compensable work-related ailment under the Workmen’s Compensation Act.
- Whether the presumption of compensability—that an illness arising during employment is work-related unless conclusively proven otherwise—applies to the petitioner’s case despite the respondent’s contention that cataract, as a result of natural aging, is non-compensable.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)