Facts:

In the case of Kindipan Belleng vs. Republic of the Philippines (City Engineer of Baguio), G.R. No. L-19856, the appellant, Kindipan Belleng, a laborer with over thirty years of service in the Office of the City Engineer of Baguio, sustained serious injuries when he was bitten by a snake, resulting in the amputation of one of his legs. Following this incident, Belleng filed a claim under the Workmen's Compensation Act against the "Republic of the Philippines - City Engineer of Baguio," which was docketed as BWC Case No. 1516-R01. The claim was uncontroverted, and an award totaling P3,088.27 was granted to him through a resolution rendered on January 3, 1962, by the Workmen's Compensation Commission. Despite the clear ruling, the City Engineer's office did not execute the order. In response, Belleng petitioned the Court of First Instance of Baguio City to enforce the award. The respondents, represented by the Solicitor-General, did not oppose this petition,

...

Facts:

Background of the Case

• The case involves a pauper’s appeal for the enforcement of a final award in the sum of P3,088.27.
• The award was granted by the Workmen’s Compensation Commission against the Republic of the Philippines (City Engineer of Baguio).

Factual Matrix

• Kindipan Belleng, a laborer with over thirty years of service at the Office of the City Engineer of Baguio, suffered a snake bite that necessitated the amputation of one of his legs.
• Belleng filed a claim under the Workmen’s Compensation Act against his employer, which was docketed as BWC Case No. 1516-R01, and the claim remained uncontroverted throughout the proceeding.

Proceedings Before the Courts

• On January 3, 1962, an Associate Commissioner of the Workmen’s Compensation Commission, after holding an ex parte hearing, rendered a resolution and award in favor of the appellant.
• On January 29, 1962, the appellant requested compliance with the award from the City Engineer of Baguio, which was disregarded.
• Consequently, the appellant sought judicial enforcement by filing a petition before the Court of First Instance of Baguio City.

Judicial Actions and Developments

• The Court of First Instance issued judgment in favor of the appellant and ordered the issuance of a writ of execution.
• The sheriff executed the writ by serving it upon the City Engineer’s Office.
• On March 29, 1962, a motion to quash and/or stay the execution, filed by the Solicitor-General, was sustained over the appellant’s objection.
• The appellant filed a motion for reconsideration, but on April 27, 1962, the court reaffirmed its position, directing that the proper remedy lay in filing a claim before the Auditor-General’s Office.

Statutory and Legal Framework

• The Workmen’s Compensation Act applies to certain government employees, laborers in public works, industrial concerns of the government, and other manual laborers in the service of the National Government and its subdivisions (Sec. 2, Act 3428, as amended).
• The Act vests exclusive jurisdiction in the Workmen’s Compensation Commissioner for hearing and deciding claims (Sec. 46, Act 3428, as amended).
• Despite this, enforcement of the award is to be sought through the regular courts (Section 51, Act 3428, as amended).
• Section 53 of the Act directs government entities to deposit funds to guarantee compensation payments to injured workers, allowing disbursement through the Commissioner or his deputy.
• Section 7 of Act 3083 provides that no execution shall issue against any judgment rendered by any court against the Government, thereby preserving state immunity.

Controversial Argument by the Appellant

• The appellant contended that the Workmen’s Compensation Act, by its application, had implicitly repealed Section 7 of Act 3083, thus waiving the state’s immunity from execution.
• The Court found this argument untenable, emphasizing that government consent to be sued did not equate to a waiver of the condition preventing judicial execution.

Issue:

Whether the final award rendered by the Workmen’s Compensation Commission could be enforced by way of a writ of execution against the Government, despite its consent to be sued under the Act.

• The issue examines the conflict between the enforcement mechanism of the Workmen’s Compensation Act and the immunity provision contained in Section 7 of Act 3083.

Whether the acceptance of suit under the Workmen’s Compensation Act by the Government implies a consent to all judicial remedies, including the issuance of a writ of execution.

• The central inquiry is if the state’s consent to be sued under a special law implicitly waives its immunity from execution that is otherwise preserved by a general law.

The availability of alternative remedies for the claimant in light of the restrictions on the issuance of execution against the Government.

• The issue also considers the procedural remedy provided by Section 53 of the Workmen’s Compensation Act (i.e., the disbursement from the compensation guarantee fund or filing a claim before the Auditor-General).

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)