G.R. No. L-27155 - Philippine National Bank vs. Court of Appeals

Cesar M. Pablico was employed by Century Insurance Company, Inc. as an accountant from June 1, 1950, to December 6, 1958, earning a monthly salary of P500.
On July 1, 1957, Pablico notified his employer of his illness and requested to be laid off with the hope of reinstatement upon recovery.
On December 22, 1958, while still employed, Pablico submitted a written notice stating that he had contracted pulmonary tuberculosis during the course of his employment, also reiterating that he had orally notified his employer on July 1, 1957.

A photostatic copy of Pablico’s notice of injury/sickness along with his claim for compensation was presented as Exhibit “A.”
The Workmen’s Compensation Section received and processed the claim: on December 23, 1958, upon receiving the duly completed formal claim, the Section informed the manager of Century Insurance Company, Inc. through Exhibit “B.”
The notice of the claim reached the insurer on January 2, 1959.

Upon notification of the claim, Century Insurance Company’s attorney communicated that the claim would be controverted, arguing non-compliance with conditions precedent—specifically, that the claim was belated.

Asserted that Pablico’s claim was presented 17 days after his separation from employment (December 6, 1958).
Argued that the delay amounted to one year, five months, and 22 days from the date he first gave notice of his illness (July 1, 1957).

On January 10, 1959, the attorney filed a motion to dismiss the claim with the Regional Office No. 3 on the grounds of tardiness and non-compliance with Section 24 of Act No. 3428 (as amended), which required that compensation claims be presented within two months from the date of injury or sickness.
The hearing officer denied both the motion to dismiss on May 11, 1959, and a subsequent motion for reconsideration on May 26, 1959.

Century Insurance Company, Inc. sought certiorari and issued a petition for prohibition before the Court of First Instance of Manila.
The petitioner alleged that:

Pablico’s services terminated on December 6, 1958.
The compensation claim was filed on December 23, 1958—well beyond the period specified by law.
Under Section 24 of Act No. 3428, the claim should have been presented within two months from the date of injury or sickness.
The delayed filing rendered the claim barred by the Statute of Limitations, and the hearing officers had thereby acted without jurisdiction and with grave abuse of discretion.

The petitioner requested an injunction to enjoin the defendants from hearing or deciding the claim, alleging that the claim’s timeliness was jurisdictional in nature.

Errors regarding application of evidence or judgment in the exercise of jurisdiction are not subject matter for a certiorari proceeding.
The late filing was not a jurisdictional defect but a factual issue that should be addressed during the claim’s regular adjudication.
There existed an alternative remedy through the appeal process within the Workmen’s Compensation Commission.

Contending that the timeliness issue was a preliminary fact to be resolved at the hearing of his compensation claim.
Denying that the officers had acted without or in excess of their jurisdiction.
Arguing that the proper remedy for any error in the proceedings was to appeal the decision of the regional offices.

Whether the jurisdiction or power of the Workmen’s Compensation Commission to hear and decide a claim is dependent on the timely presentation of the claim as required by Section 24 of Act No. 3428.
Whether the failure to present a claim within the prescribed two-month period results in a jurisdictional defect or merely affects the merits of the claim.

Whether errors involving the determination of timeliness (and thus conditions precedent) expose the hearing officers to be said to have acted without jurisdiction.
Whether such errors can serve as a ground for a certiorari proceeding aimed at enjoining the Commission from hearing the claim.

Whether the petitioner’s remedy—seeking certiorari and a permanent injunction against the Commission’s officers—is proper when there is an alternative plain, speedy, and adequate remedy (the appeal process).
Whether the error in assessing the filing period should be corrected by a writ of prohibition or through the appellate process, given that jurisdiction involves the authority to hear a case irrespective of errors in its exercise.