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...

Facts:

Parties Involved

• Petitioner: A. V. H. & Company of the Philippines (“the Company”).
• Respondents:
• The Workmen’s Compensation Commissioner (Mariano B. Alumno).
• The Sheriff of Manila.
• The Sheriff of Pasay City.

Incident and Initial Claim

• On October 23, 1958, respondent Mariano B. Alumno, employed as a laborer by the Company, sustained injuries to his right hand while performing his duties.
• Respondent filed a notice of injury or sickness along with a claim for compensation with the Regional Office No. 3 of the Department of Labor.

Administrative Proceedings and Awards

• The Administrator of Regional Office No. 3 initially rendered an award on March 12, 1958, awarding Alumno compensation amounting to P206.91.
• Following a petition for reconsideration filed by the Company, the award was reduced to P161.31 on May 27, 1959.
• A subsequent motion for further reconsideration did not succeed, and on June 25, 1959, the normalized record was forwarded to the Workmen’s Compensation Commission.

Commission Decision and Enforcement Actions

• On June 22, 1960, an Associate Commissioner issued a decision ordering the Company to pay Alumno P849.09 plus additional fees of P14.00.
• No appeal was taken against this decision by the Company.
• On August 18, 1960, the Commission executed a writ of execution directing the Sheriff of Manila to seize the Company’s personal effects up to the amount adjudged.
• On September 8, 1960, another writ of execution was issued to the Sheriff of Pasay City, reinforcing the enforcement action.

Petition for Prohibition and Court Proceedings

• On or about September 13, 1960, the Company filed an action for prohibition in the Court of First Instance of Manila.
• The petition sought to nullify the decision of June 22, 1960, and the subsequent writs of execution on grounds of constitutional and procedural improprieties.
• The Company challenged the constitutionality of Act No. 3428 in so far as it authorized the Workmen’s Compensation Commission to render decisions and issue enforceable writs.
• The petition further requested a writ of preliminary injunction to restrain the sheriffs from executing the writs pending resolution of the case.

Pre-hearing Developments and Court’s Initial Ruling

• Upon setting the petition on due course with a scheduled hearing for the preliminary injunction, respondents filed motions to:
• Dismiss the case on the ground of insufficiency in both substance and form.
• Argue that the Company had neither appealed the Commission’s decision promptly nor objected to its jurisdiction.
• Subsequently, on September 23, 1960, the lower court ruled against the Company’s petition on prohibition, citing procedural defaults.

Appeal and Relief Sought

• The Company, dissatisfied with the Court of First Instance’s ruling, elevated the matter by filing an appeal with the Supreme Court, characterizing it as an “appeal by certiorari”.
• In its appeal, the Company reiterated its claim that:
• Act No. 3428 (as amended) is unconstitutional insofar as it empowers the Workmen’s Compensation Commissioner to issue an enforceable decision.
• Reorganization Plan No. 20-A (in conjunction with Republic Act No. 997) is invalid.
• The Commissioner acted without or in excess of jurisdiction by issuing the writs of execution.

Issue:

Constitutional Validity

• Is Act No. 3428, as amended, unconstitutional to the extent that it authorizes the Workmen’s Compensation Commission to render enforceable decisions and issue writs of execution?
• Is Reorganization Plan No. 20-A, particularly the provisions enabling the Commission to issue such writs, similarly unconstitutional?

Delegation of Judicial Powers

• Does the delegation of power to an administrative agency (the Workmen’s Compensation Commission) — an agency within the executive department — to issue enforceable decisions, effectively amount to an impermissible delegation of judicial powers?
• Can writs of execution be properly issued by an administrative body rather than by a court of justice?

Procedural Compliance

• Did the Company fail in procedural terms by not appealing the Commission’s decision or addressing its alleged lack of jurisdiction at the proper stage, thereby affecting its right to seek prohibition?
• Can the substantive nullity of the writs of execution nullify procedural defects in the Company’s petition for prohibition?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)