Case Digest (G.R. No. L-44108)
Facts:
- Benjamin Z. Villanueva (deceased; represented by wife Beata Tabano) is the petitioner.
- Respondents are the Workmen's Compensation Commission and the Republic of the Philippines (Land Transportation Commission).
- Villanueva, a former MV Registrar III, was declared "totally and permanently disabled" by GSIS and retired on February 1, 1974, at age 60.
- After retirement, he faced health issues, including dizziness and back pain, leading to hospitalization from February 3 to March 7, 1974.
- Diagnosed with upper respiratory tract infection and viral encephalomyelitis, he had a relapse from December 24, 1974, to January 6, 1975.
- On September 13, 1974, he filed a claim for disability benefits under the Workmen's Compensation Act.
- The Acting Referee ruled in favor of Villanueva on October 30, 1975, citing a substantial connection between his employment and illness.
- The Republic filed a petition for relief from judgment on January 17, 1976, claiming excusable negligence for not appealing.
- The Workmen's Compensation Commission reversed the referee's decision on February 18, 1976, stating Villanueva was no longer an employee at the time of illness.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled in favor of the petitioner, reinstating the Acting Referee's decision dated October 30, 1975, with an increase in attorney's fees to P600.00.
- The Court held that the Commission lack...(Unlock)
Ratio:
- The Court's decision focused on the jurisdictional issue regarding the finality of the Acting Referee's award.
- The award became final when the Republic failed to file a motion for reconsideration or appeal within the 15-day period after receiving the decision.
- The Court noted that while the Revised Rules of the Workmen's Compensation Commission allows for a petition for relief...continue reading
Case Digest (G.R. No. L-44108)
Facts:
The case involves Benjamin Z. Villanueva (deceased; substituted by his wife Beata Tabano) as the petitioner against the Workmen's Compensation Commission and the Republic of the Philippines (Land Transportation Commission) as respondents. The events leading to the case began when Villanueva, a former employee of the Land Transportation Commission with the designation of MV Registrar III, was declared "totally and permanently disabled" by the Government Service Insurance System (GSIS) and approved for retirement effective February 1, 1974, at the age of 60. Shortly after his retirement, on February 3, 1974, he experienced various health issues, including dizziness, back pains, and general body weakness, which led to his hospitalization at the Siliman University Medical Center in Dumaguete City. He was diagnosed with several conditions, including upper respiratory tract infection and viral encephalomyelitis, and was confined from February 3 to March 7, 1974, with a relapse occurring later from December 24, 1974, to January 6, 1975.
On September 13, 1974, Villanueva filed a claim for disability benefits under the Workmen's Compensation Act with the Department of Labor, Regional Office No. 8 in Cebu City. The Acting Referee, Jess B. Gador, ruled in favor of Villanueva on October 30, 1975, stating that there was a substantial connection between his employment and his illness. The referee ordered the Republic to pay Villanueva various amounts for temporary total disability compensation, medical expenses, attorney's...