Case Digest (G.R. No. L-43024)
Facts:
Maria V. Dimagiba (petitioner) was employed by the Central Bank of the Philippines (respondent) starting September 26, 1955, and was promoted through various positions, ultimately becoming a Senior Clerk with an annual salary of P4,980.00. In 1964, while performing her job, Dimagiba developed a medical condition diagnosed as "Diabetes Mellitus, Hypercholesternina, GBD." This condition caused her to frequently take sick leave and, upon her doctor’s advice, she resigned from her position on June 15, 1970. On October 7, 1970, she filed a claim for disability compensation under the Workmen’s Compensation Act due to her illness. The Central Bank filed its response, disputing the claim, on October 12, 1970. Following a series of hearings led by Acting Referee Vivencio E. Escarcha, a decision was rendered on July 17, 1972, ordering the Bank to pay Dimagiba P6,000.00 for total permanent disability and reimburse her medical expenses amounting to P22,299.65. The Bank received th
Case Digest (G.R. No. L-43024)
Facts:
- Maria V. Dimagiba, the petitioner, was a former employee of the Central Bank of the Philippines beginning on September 26, 1955.
- She was initially employed as a Clerk in the Import Department, later promoted to Supervising Clerk in the Loans and Credit Department on March 1, 1966, and finally elevated to Senior Clerk with an annual salary of P4,980.00.
Background and Employment
- Sometime in 1964, while actively engaged at work, petitioner developed an illness diagnosed as "Diabetes Mellitus, Hypercholesternina, GBD" by her attending physician.
- The illness forced her to take intermittent sick leaves and undergo regular medical treatment.
- Following her physician’s advice, she tendered her resignation from government service on June 15, 1970.
Onset of Illness and Resignation
- Petitioner filed her claim for disability compensation under the Workmen’s Compensation Act on October 7, 1970.
- In response, the respondent (Central Bank) filed its controversion on October 12, 1970.
Filing of Disability Compensation Claim
- After hearings and presentation of evidence, Acting Referee Vivencio E. Escarcha of Regional Office No. 4 rendered a decision on July 17, 1972.
- The decision ordered the Bank to pay the petitioner a compensation of P6,000.00 for total permanent disability plus reimbursement of medical expenses amounting to P22,299.65.
- The deciding order also awarded attorney’s fees of P300.00 to Atty. Ricardo Perez and administrative fees of P61.00.
- The decision was communicated to the respondent Bank on August 7, 1972.
Decision of the Acting Referee
- On August 21, 1972, the respondent Bank filed a Motion to Extend Time for Filing Petition for Review, requesting a 10-day extension from August 22, 1972, due to the unavailability of the transcript of stenographic notes.
- The Acting Referee granted the extension on August 22, 1972, which set the new deadline at September 1, 1972.
- On September 7, 1972, the respondent filed a second motion requesting another 10-day extension on the grounds of the transcript's unavailability; however, this motion was filed 6 days after the expiration of the permitted period.
- On October 13, 1972, the respondent Bank filed its Petition for Reconsideration, again beyond the reglementary period.
- Consequently, on October 16, 1972, the Acting Referee issued an order declaring his decision final and unappealable.
Motions for Extension and Filing of Reconsideration
- Respondent Bank filed a Petition for Review of the order on November 15, 1972, which was met with opposition by the petitioner on November 27, 1972.
- A reply by the respondent followed on November 29, 1972.
- On March 26, 1974, the Acting Referee denied the respondent’s petition for reconsideration regarding the order declaring the decision final.
- Respondent Bank then filed a "Petition for Relief from Order and to Elevate Records" with the Workmen’s Compensation Commission on April 3, 1974.
- The petitioner opposed on February 5, 1975, and an urgent motion was filed.
- The Acting Referee elevated the records to the Commission on October 17, 1975, leading to the Commission issuing its decision on January 30, 1976.
Subsequent Proceedings and Relief Petitions
- The Commission modified the original award by granting a total of P8,154.95 for disability and medical expenses.
- Attorney’s fees were set at P600.00, with an administrative fee of P66.00 imposed.
- Petitioner contested the Commission’s review of the decision, arguing that the award had attained finality and executory status.
Award by the Workmen’s Compensation Commission
Issue:
- Whether the decision of the Acting Referee dated July 17, 1972 became final and executory upon the lapse of the 15-day period.
- Whether the motions for extension and petition for reconsideration filed by the respondent Bank timely preserved its right to appeal.
Finality of the Acting Referee’s Decision
- Whether the Commission rightfully acquired jurisdiction to review and modify the Acting Referee’s award despite its finality.
- Whether the application of the new rules (e.g., Rule 22 of the Rules of the Workmen’s Compensation Commission effective March 8, 1973) can retrospectively suspend the running of the appeal period.
Jurisdiction of the Workmen’s Compensation Commission
- Whether the unavailability of the transcript of stenographic notes is a sufficient ground for filing late motions for extension or petition for reconsideration.
- Whether the respondent Bank’s failure to independently verify the status of its motion for extension justifies the delay.
Validity of Respondent Bank’s Grounds for Extension
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)