Case Digest (G.R. No. L-17502)
Facts:
The case involves A. V. H. & Company of the Philippines as the petitioner and the Workmen's Compensation Commissioner, Mariano B. Alumno, along with the Sheriffs of Manila and Pasay City as respondents. The events leading to this case began on October 23, 1958, when Mariano B. Alumno filed a notice of injury and a claim for compensation against A. V. H. & Company due to injuries he sustained to his right hand while performing his duties as a laborer for the company. Following the filing, the Regional Office No. 3 of the Department of Labor awarded Alumno P206.91 for his injuries on March 12, 1958. However, after the company filed a petition for reconsideration, the amount was reduced to P161.31 on May 27, 1959. The company’s subsequent motion for reconsideration was denied, and the case was forwarded to the Workmen's Compensation Commission on June 25, 1959. On June 22, 1960, the Commission ordered the company to pay Alumno P849.09, plus P14.00 in fees. The co...
Case Digest (G.R. No. L-17502)
Facts:
- Injury and Claim: On October 23, 1958, Mariano B. Alumno, a laborer employed by A. V. H. & Company of the Philippines (the Company), filed a notice of injury and claim for compensation with Regional Office No. 3 of the Department of Labor. He sustained injuries to his right hand while performing his duties.
- Initial Award: On March 12, 1958, the Administrator of the Regional Office awarded Alumno P206.91 as compensation.
- Reduction of Award: Upon the Company's petition for reconsideration, the award was reduced to P161.31 on May 27, 1959.
- Final Decision by Workmen's Compensation Commission: On June 22, 1960, an Associate Commissioner of the Workmen's Compensation Commission rendered a decision ordering the Company to pay Alumno P849.09, plus P14.00 as fees. No appeal was taken from this decision.
- Writs of Execution: On August 18, 1960, and September 8, 1960, the Commission issued writs of execution directing the Sheriffs of Manila and Pasay City to seize the Company's personal effects to satisfy the award.
- Petition for Prohibition: On September 13, 1960, the Company filed a petition for prohibition with the Court of First Instance of Manila, seeking to annul the Commission's decision and writs of execution. The Company argued that Act No. 3428 was unconstitutional for delegating judicial powers to an administrative body and that only courts could issue writs of execution.
- Dismissal of Petition: The Court of First Instance dismissed the petition, holding that the Company failed to appeal the Commission's decision or challenge its jurisdiction.
Issue:
- Whether Act No. 3428, as amended, is unconstitutional for authorizing the Workmen's Compensation Commission to render enforceable decisions.
- Whether Reorganization Plan No. 20-A, in relation to Republic Act No. 997, is invalid.
- Whether the Workmen's Compensation Commission acted in excess of or without jurisdiction in issuing the writs of execution.
Ruling:
The Supreme Court set aside the order of the Court of First Instance and declared the writs of execution null and void. The writ of preliminary injunction issued by the Supreme Court was made permanent.
- Constitutionality of Act No. 3428: The Court held that Act No. 3428 does not authorize the Workmen's Compensation Commission to issue enforceable decisions. Instead, if an employer fails to comply with the Commission's decision, a certified copy of the decision must be filed with the proper court of first instance, which will then render a judgment enforceable by writ of execution.
- Invalidity of Reorganization Plan No. 20-A: The Court reaffirmed its earlier ruling that the portion of Reorganization Plan No. 20-A authorizing the Commission to issue writs of execution is unconstitutional.
- Jurisdiction of the Commission: The Court found that the Commission acted without jurisdiction in issuing the writs of execution, as this power is reserved for courts.
Ratio:
- Separation of Powers: The issuance of writs of execution is a judicial function that cannot be delegated to an administrative body like the Workmen's Compensation Commission.
- Procedural Compliance: While the Company failed to follow procedural requirements for a writ of prohibition, the Court ruled that the patent nullity of the writs of execution justified setting aside the lower court's dismissal.
- Judicial Enforcement: Decisions of the Workmen's Compensation Commission must be enforced through the courts, not directly by the Commission.