La Mallorca v. Ramos
REITERATIONFacts
1. The Antecedents: Respondent Nicanor Ramos, a driver for petitioners La Mallorca and Pampanga Bus Company, Inc., filed a claim for compensation due to disability from tuberculosis, alleging it was contracted or aggravated by his employment. The Regional Office No. 3 of the Department of Labor awarded him P1,862.00 in disability compensation and P19.00 in fees. 2. Procedural History: Petitioners sought a writ of prohibition from the Court of First Instance of Manila to prevent the enforcement of the Regional Office's decision, arguing the office lacked jurisdiction. The trial court granted the writ, vacating the decision. Respondents appealed this judgment to the Supreme Court. 3. The Petition: The respondents' appeal to the Supreme Court argues that the trial court erred in granting the writ of prohibition. They contend that Reorganization Plan No. 20-A, enacted under Republic Act No. 997, grants the Regional Office jurisdiction over such claims under the Workmen's Compensation Act. The Supreme Court is asked to determine the validity of this jurisdiction and the enforceability of the Regional Office's decision.
Issue(s)
Whether the Regional Office No. 3 of the Department of Labor had jurisdiction to hear and decide the claim for compensation under the Workmen's Compensation Act. Whether the trial court erred in granting the writ of prohibition.
Ruling
The judgment of the Court of First Instance is reversed. The petition for prohibition is dismissed. The decision of the Regional Office No. 3 of the Department of Labor ordering the petitioners to pay respondent Nicanor Ramos disability compensation is declared valid and binding.
Ratio Decidendi
On the jurisdiction of Regional Office No. 3: The Supreme Court held that the Regional Offices created under Reorganization Plan No. 20-A, undertaken pursuant to Republic Act No. 997, as amended, do have original jurisdiction to hear and decide claims for compensation falling under the Workmen's Compensation Law (Act No. 3428, as amended). The Court reasoned that the jurisdiction vested by the Workmen's Compensation Act on the Workmen's Compensation Commission has not been revoked, either expressly or by necessary implication, by Republic Act No. 992, as amended, or any subsequent statute. Furthermore, the regional offices created under Reorganization Plan No. 20-A partake of the nature of referees which the Workmen's Compensation Commission had the right to appoint and clothe with jurisdiction to hear and decide such claims, as provided in Section 48 of Act No. 3428, as amended. Therefore, the provisions of Reorganization Plan No. 20-A, insofar as they confer on said regional offices jurisdiction over claims for compensation falling under the Workmen's Compensation Law, are perfectly legal, and their decisions on such claims are valid and binding. The Court distinguished this from previous pronouncements which declared null and void the grant of jurisdiction to regional offices over money claims of laborers other than those falling under the Workmen's Compensation Law. On the trial court's error in granting the writ of prohibition: Based on the established jurisdiction of the Regional Office over claims under the Workmen's Compensation Act, the Supreme Court found that the trial court erred in issuing the writ of prohibition restraining the enforcement of the decision of Regional Office No. 3. The Court noted that the petitioners filed the action for prohibition immediately after being notified of the decision, and it could not be assumed that the Commissioner would attempt to enforce the decision without following the prescribed procedure under Section 51 of the Workmen's Compensation Law, Act No. 3428, as amended. Thus, the writ of prohibition was improperly granted.
Main Doctrine
Regional Offices created under Reorganization Plan No. 20-A, undertaken pursuant to Republic Act No. 997, as amended, have original jurisdiction to hear and decide claims for compensation under the Workmen's Compensation Act, as the jurisdiction vested by Act No. 3428, as amended, on the Workmen's Compensation Commission has not been revoked, and said regional offices partake of the nature of referees which the Workmen's Compensation Commission had the right to appoint.