Suataron v. Hawaiian-Philippine Company
REITERATIONFacts
1. The Antecedents: Pacita Salabaria Vda. de Suataron, on behalf of herself and her minor children, filed a petition for a writ of execution to enforce an award from the Workmen's Compensation Commission (WCC), which had been affirmed by the Supreme Court and had become final and executory. The total award was P2,171.52 plus P100.00 for burial expenses. The respondent, Hawaiian-Philippine Company, had allegedly paid only P765.19, leaving a balance of P1,506.33 plus interest. 2. Procedural History: The respondent, in its amended answer, claimed that the petitioner had withdrawn various sums totaling P1,519.45 while the claim was pending, which were payments on account of the compensation. After the award became final, the respondent remitted P792.19 to the WCC. The parties submitted a stipulation of facts. The trial court denied the respondent's motion to dismiss and ordered the issuance of the writ of execution, holding that its function under Section 51 of Act No. 3428, as amended by Republic Act No. 772, was ministerial. The respondent appealed, and the trial court initially denied the appeal as unappealable but later allowed it, suspending the writ of execution. 3. The Petition: The case reached the Supreme Court on appeal, involving a question of law. A key stipulated fact was that the petitioner had received P1,750.00 through vouchers signed by her, which contained notations stating the amounts were voluntary donations and not an admission of legal liability by the company. The core issue was whether these amounts should be construed as payments settling the compensation liability or as voluntary donations.
Issue(s)
Whether the amounts received by the petitioner under vouchers with notations of "voluntary donation" should be construed as payments in settlement of the respondent's compensation liability. Whether the court's function in enforcing a final award of the Workmen's Compensation Commission is merely ministerial.
Ruling
The Supreme Court dismissed the appeal and affirmed the trial court's order denying the motion for reconsideration and ordering the issuance of the writ of execution. The Court held that the function of the court in enforcing a final award of the Workmen's Compensation Commission is purely ministerial.
Ratio Decidendi
On the issue of whether the amounts received by the petitioner under vouchers with notations of "voluntary donation" should be construed as payments in settlement of the respondent's compensation liability: The Court held that since these partial payments were made before the finality of the award or while it was pending review, the respondent should have raised this matter before the award became final and executory. The proper time for the respondent to have raised the question of whether these payments were advances or mere voluntary donations was when the award was affirmed by the Supreme Court and the case was returned to the Workmen's Compensation Commission for enforcement. The Commission would then have had the opportunity to determine the issue and make the corresponding adjustment. As the case stood, the award had become final and executory, and the court's function was merely to enforce it as mandated by law. On the issue of whether the court's function in enforcing a final award of the Workmen's Compensation Commission is merely ministerial: The Court affirmed the trial court's interpretation of Section 51 of Act No. 3428, as amended by Republic Act No. 772. This provision clearly states that when a party in interest files a certified copy of a final decision of the WCC, the court shall render a decree or judgment "in accordance therewith." The law further specifies that "there shall be no appeal therefrom." This indicates that the court's role is to enforce the award as certified by the commissioner, not to modify or alter it based on claims of deduction or alleged payments made during the pendency of the proceedings. Allowing such claims would render the decree controversial and subject to appeal, which the law expressly prohibits.
Main Doctrine
The function of a court in enforcing a final and executory award from the Workmen's Compensation Commission is merely ministerial, limited to rendering a decree or judgment in accordance with the award, and it cannot entertain claims for deduction or modification of the award, especially when such claims could have been raised during the pendency of the proceedings before the award became final.