G.R. No. L-41949 - Ramos vs. Republic

On July 25, 1974, the Acting Chief Referee of the respondent commission issued an Award in favor of petitioner-claimant Jacinta J. Ramos, a former proofreader.
The Award declared her claim uncontroverted and granted her disability compensation of P6,000.00 for neuro-circulatory asthenia with slight heart enlargement and hepatitis, plus an administrative fee of P61.00.
The Award was directed to the respondent Bureau of Census and Statistics, which was represented by the Solicitor General’s office.

A copy of the Award was received on October 31, 1974.
Since no motion for reconsideration or review was filed within fifteen days, the Award became final and executory on November 15, 1974.
The finality of the Award was underscored by procedural rules, ensuring that the decision was binding unless challenged within the prescribed reglementary period.

On November 14, 1974, respondent counsel filed a motion for clarification regarding the total liability under the Award.
On November 29, 1974, the commission issued a clarifying Order limiting respondent’s liability to the maximum disability compensation of P6,000.00 under sections 17 and 18 of the Workmen’s Compensation Act.
On December 6, 1974, respondent counsel informed the respondent that, barring any legal impediments in the Bureau’s records, the Award and costs were now payable.

On January 23, 1975, well after the Award had become final and executory, respondent bureau filed a motion to set aside the Award.
The motion claimed that a timely controversion had been made on June 28, 1974, contending that a previous Notice of Controversion on June 20, 1974 had been “out of time.”
Petitioner filed an Opposition on March 7, 1975, asserting that the commission no longer had jurisdiction since the Award was final.
Although a Hearing Officer later found the motion “not to be meritorious,” the record was still elevated for further review by the commission.

On October 24, 1975, the Workmen’s Compensation Commission reviewed the case despite the Award’s finality.
The commission based its reversal on assertions and documents submitted with respondent’s belated motion, including claims concerning petitioner’s alleged absence and resignation.
Without a proper explanation or justification for disregarding the Award’s finality, the commission reversed the referee’s decision, absolving the respondent of any liability.

Whether the Workmen’s Compensation Commission had jurisdiction and authority to set aside an Award that had already become final and executory.
Whether the respondent’s claim of a timely controversion was valid given that the motion to set aside was filed after the expiration of the reglementary period.

Whether respondent counsel’s filing of a motion for clarification and subsequent endorsement for payment constituted a waiver of the right to a hearing on the Award.
How these actions affected the compensability of the claim originally established in the Award.

The significance of the reglementary deadline in safeguarding the finality of judicial and quasi-judicial decisions.
Whether the principles of public policy and sound administrative practice mandate strict adherence to finality once an Award is rendered final and executory.