Case Summary (G.R. No. L-17502)
Case Overview
- Court: Supreme Court of the Philippines
- Date: May 30, 1962
- Case Number: G.R. No. L-17502
- Petitioner: A. V. H. & Company of the Philippines
- Respondents: Workmen's Compensation Commissioner Mariano B. Alumno, Sheriff of Manila, Sheriff of Pasay City
Procedural Background
- The Court was presented with an appeal from an order of the Court of First Instance of Manila dismissing a petition for prohibition filed by the petitioner.
- The initial claim for compensation was filed by Mariano B. Alumno for injuries sustained while working for the Company.
- Compensation awards were issued and subsequently modified, leading to the issuance of writs of execution against the Company for non-compliance.
Claims and Awards
- Initial Claim: Filed by Alumno on October 23, 1958, for a hand injury.
- Compensation Award: Originally P206.91, later reduced to P161.31 upon reconsideration.
- Final Decision: On June 22, 1960, the Workmen's Compensation Commission ordered the Company to pay P849.09 plus P14.00 in fees.
Appeal for Prohibition
- The Company filed for prohibition on September 13, 1960, arguing:
- Act No. 3428 is unconstitutional for delegating judicial powers to an administrative body.
- Only courts of justice can issue writs of execution.
- The Court initially gave due course to the petition but later dismissed it, citing the Company's failure to appeal the Commission’s decision.
Supreme Court Findings
Jurisdiction and Authority of the Commission
- The Court ruled that the Workmen's Compensation Act does not allow the Commission to issue enforceable decisions without a court's decree.
- Emphasized that if an employer does not comply with the Commission’s decision, the proper action is to file a certified copy with the Court of First Instance for enforcement.
Unconstitutionality of Execution Writs
- The Court found the writs of execution issued by the Commission to be null and void, referencing prior cases that determined such authority unconstitutional.
- The enforcement of the Commission's decision was not valid without a court judgment.
Key Legal Principles
- Prohibition: A legal remedy to prevent unlawful actions by public officials.
- Writ of Execution: A court order to enforce a judgment, which was incorrectly issued by the Commission in this case.
- Enforceable Decision: A decision that allows for immediate execution, which the Court clarified does not apply to the Commission's decisions.
Important Procedural Requirements
- The Company’s failure to appeal the Commission’s decision was noted; procedural requirements for seeking prohibition were not met.
- However, the nullity of the writs was so apparent that the dismissal on procedural grounds was not upheld.
Conclusion of the Court
- The Supreme Court set aside the lower court's order, declared the writs of execution null and void, and made the preliminary injunction permanent.
Key Takeaways
- The decision highlights
Case Syllabus (G.R. No. L-17502)
Case Overview
- This case involves an appeal from an order by the Court of First Instance of Manila that dismissed a petition for prohibition filed by A. V. H. & Company of the Philippines against various respondents including the Workmen's Compensation Commissioner and the Sheriffs of Manila and Pasay City.
- The central issue revolves around the validity of the decisions rendered by the Workmen's Compensation Commission and the writs of execution issued based on those decisions.
Factual Background
- On October 23, 1958, Mariano B. Alumno filed a notice of injury and claim for compensation against A. V. H. & Company for injuries sustained while working as a laborer.
- An initial award was granted on March 12, 1958, amounting to P206.91, which was later reduced to P161.31 after the Company filed for reconsideration.
- The case was escalated to the Workmen's Compensation Commission, which on June 22, 1960, ordered the Company to pay Alumno P849.09 plus additional fees.
- The Company did not appeal this decision, leading to the issuance of writs of execution for the collection of the awarded amount.