Title
Alhambra Cigar and Cigarette Manufacturing Co., Inc. vs. National Administrator of Regional Office No. 2
Case
G.R. No. L-20491
Decision Date
Aug 31, 1965
Driver Francisco Atip claimed compensation for illness under the Workmen's Compensation Act; labor officials' jurisdiction upheld by the Supreme Court, reversing lower court's prohibition.
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Case Digest (G.R. No. L-20491)

Facts:

    Background of Employment and Illness

    • Francisco Atip was employed by Alhambra Cigar and Cigarette Manufacturing Company, Inc. as a driver, earning a salary of P120.00 a month until his resignation in December 1955.
    • After his regular employment ended, he occasionally rendered services as a casual driver for the company in July, August, and September 1957, being paid per trip.
    • As early as July 2, 1954, Atip gave verbal notice to the petitioner-appellee of his sickness, and in July 1955 he complained of his illness.
    • On one of his trips to Manila, he was examined by Dr. Pacifico Franco, the company physician, who detected high blood pressure and noted cardiac enlargement on X-ray examination.
    • Following the medical findings, Atip was advised to be confined and treated at St. Luke’s Hospital, where he was admitted from July 5 to July 11, 1955, and again from September 29 to October 6, 1955, all at the company’s expense.

    Filing of the Compensation Claim

    • On October 22, 1959, Atip filed a “notice of injury or sickness and claim for compensation” under the Workmen’s Compensation Act with the Regional Office No. 2 of the Department of Labor at Tuguegarao, Cagayan.
    • In his claim, Atip asserted that:
    • He had provided prior verbal notice of his ailment in 1954.
    • His illness, now described as “rheumatism leading to paralysis,” prevented him from working.
    • He had received medical treatment under the petitioner-appellee’s expense at St. Luke’s Hospital.
    • Despite his resignation, he later worked on a casual basis in 1957 for which he was compensated per trip.
    • The claim was docketed as RO-2 Case No. 519-C by the Regional Office No. 2.

    Administrative and Judicial Proceedings

    • The petitioner-appellee filed a motion to dismiss Atip’s claim on the ground that it was barred under the Workmen’s Compensation Act.
    • In an order dated August 26, 1960, Hearing Officer Eugenio Caleda denied the motion to dismiss, basing his decision on the ground that Atip’s prior treatment at St. Luke’s Hospital negated the requirement for a separate notice of sickness.
    • The petitioner-appellee’s subsequent motion for reconsideration of the Hearing Officer’s order was likewise denied.
    • On January 11, 1961, the petitioner-appellee filed a petition for certiorari and prohibition with a preliminary injunction in the Court of First Instance (CFI) of Manila, aimed at restraining the Hearing Officer, the Regional Labor Administrator of Regional Office No. 2, and Atip from further proceedings in the compensation claim.
    • The CFI of Manila, Branch X, issued an ex parte writ of preliminary injunction on January 13, 1961.
    • Following further motions to dismiss by the respondents-appellants (including issues of venue and lack of a cause of action), and corresponding oppositions, the trial court denied such motions on April 21, 1961.
    • Additional pleadings ensued:
    • The respondents-appellants answered the petition on May 5, 1961.
    • Atip filed a manifestation on April 30, 1961, indicating his intention to adopt subsequent pleadings of the labor officials.
    • On August 7, 1962, the respondents-appellants filed another motion to dismiss on the ground of lack of territorial jurisdiction.
    • Atip also filed a motion to dismiss on August 9, 1962, on similar grounds.
    • On September 20, 1962, the CFI of Manila rendered its decision granting the petition for certiorari and prohibition, permanently enjoining the respondent Regional Labor Administrator, the Hearing Officer, and Atip from proceeding with the compensation claim.
    • Although Atip did not appeal the decision, the Regional Administrator and the Hearing Officer subsequently appealed from the decision.

    Jurisdictional and Venue Controversy

    • The core controversy centered on whether the CFI of Manila had the jurisdiction to issue a writ of certiorari and prohibition with a preliminary injunction against officers of the Department of Labor’s Regional Office No. 2 in Tuguegarao, Cagayan.
    • The respondents argued that:
    • The officers in question were not acting within the Manila judicial district.
    • Their official acts were committed in Tuguegarao, Cagayan, which lies within the First Judicial District and not within the territorial jurisdiction of the Manila court.
    • The petitioner-appellee, however, contended that the acts of the labor officials were amenable to judicial review despite the geographical and jurisdictional issues.
    • The case raised significant questions on the appropriate venue for filing petitions involving special civil actions such as certiorari, prohibition, and injunctions, particularly when the acts in question occur outside the court’s territorial boundaries.

Issue:

    Jurisdictional Authority and Proper Venue

    • Whether the Court of First Instance of Manila had jurisdiction to issue a writ of certiorari, prohibition, and a preliminary injunction restraining officers of the Department of Labor’s Regional Office No. 2 located in Tuguegarao, Cagayan.
    • Whether proper venue was observed when the petitioner-appellee filed the petition in Manila, given that the underlying compensation claim originated in Cagayan, within the First Judicial District.

    Abuse or Excess of Jurisdiction by Labor Officials

    • Whether the actions of the Hearing Officer in denying the motion to dismiss, despite potential errors in judgment regarding the admissibility of the sick notice, constituted an excess of jurisdiction or grave abuse of discretion.
    • Whether such errors, if any, should have been remedied by the established appellate process within the framework of the Workmen’s Compensation Act rather than through a petition for certiorari and prohibition.

    Statutory and Procedural Compliance

    • Whether the actions taken by the respondent labor officials were properly supported by Sections 4, Rule 67 (or its equivalent in the then Rules of Court) and related provisions of the Judiciary Act and Reorganization Plan No. 20-A of the Department of Labor.
    • Whether the petitioner-appellee’s choice of remedy (certiorari and prohibition) was appropriate given that the issue could be correctly resolved by the labor administrative body and its appellate mechanism.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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