Shipping Corporation v. Borcelis
REITERATIONFacts
The Antecedents: Agustin Borcelis, a truck driver employed by "Y" Shipping Corporation, filed a claim for compensation for injuries sustained in the course of employment. The claim was not controverted, and an award was made by the regional administrator. Procedural History: The corporation filed a petition for review, which was denied. The award was affirmed by an associate commissioner, and a motion for reconsideration before the commission en banc was also denied. A petition for certiorari before the Supreme Court was dismissed for lack of merit. The Petition: Subsequently, a writ of execution was issued by Commissioner Jose Sanchez to enforce the award. The corporation filed a motion for recall of the writ, arguing the Commission lacked the power to issue it. This motion was denied, as was a subsequent motion for reconsideration. The corporation then filed a petition for prohibition before the Court of First Instance of Manila, which was dismissed. The present appeal stems from this dismissal.
Issue(s)
Whether the Workmen's Compensation Commission has the power to issue a writ of execution to enforce its decisions. Whether the writ of execution issued by the Workmen's Compensation Commission is null and void.
Ruling
The Supreme Court set aside the order appealed from, declaring the writ of execution issued by the Workmen's Compensation Commission null and void. No costs were awarded.
Ratio Decidendi
On the issue of whether the Workmen's Compensation Commission has the power to issue a writ of execution to enforce its decisions: The Court held that the Workmen's Compensation Commission does not possess the power to issue a writ of execution. The law provides that an interested party may file a certified copy of the referee's or Commissioner's final decision in any court of record, and it is this court that will issue a judgment based upon said decision. It is this judgment of the court that can be enforced by a writ of execution to be issued by the said court, pursuant to Section 8, Rule 39 of the Rules of Court. The powers granted to the WCC by reorganization acts cannot validly include the power to amend Section 51 of the Workmen's Compensation Law, as to do so would diminish the jurisdiction and judicial power vested by law on courts of record. The issuance of an order for the execution of a decision or award is essentially a judicial power or function of the court. On the issue of whether the writ of execution issued by the Workmen's Compensation Commission is null and void: Based on the foregoing reasoning, the writ of execution issued by the Workmen's Compensation Commission, which was the subject of the appeal, was declared null and void. The Court's decision in Pastoral vs. The Commissioners of the Workmen's Compensation Commission, et al., G.R. No. L-12903 (July 31, 1961), was cited as precedent, clearly stating that the enforcement of awards must be through a judgment rendered by a court of record.
Main Doctrine
The Workmen's Compensation Commission does not possess the power to issue a writ of execution to enforce its decisions; such power is vested in courts of record after a judgment has been rendered based on the Commission's decision.