Famorca v. Commissioner, Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: A claim for P335.57 under the Workmen's Compensation Act was filed by Ernesto Sison for an injury sustained while in the employ of Valerio Famorca. The claim was not controverted, and the Workmen's Compensation Commission (WCC) awarded the sum claimed. Procedural History: The award became final due to the lack of an appeal. The WCC ordered the execution of the award and directed the deputy sheriff of Kiangan, Mountain Province, to carry it out. Valerio Famorca filed a petition for a writ of prohibition to prevent the WCC and the deputy sheriff from executing the award. The Court of First Instance granted the writ. The Petition: The respondents-appellants appealed the judgment of the Court of First Instance to the Supreme Court.
Issue(s)
Whether the Workmen's Compensation Commission (WCC) has the power to issue a writ of execution for its awards or decisions.
Ruling
The Supreme Court affirmed the judgment of the Court of First Instance, upholding the grant of the writ of prohibition. The Court ruled that the Workmen's Compensation Commission does not have the power to issue writs of execution for its awards.
Ratio Decidendi
On Issue 1: The Supreme Court affirmed the ruling that the Workmen's Compensation Commission (WCC) lacks the power to issue writs of execution for its awards or decisions. Citing Pastoral vs. The Commissioners of the Workmen's Compensation Commission, et al. (G.R. No. L-12903, 31 July 1961), the Court reiterated that Section 51 of Act No. 3428, as amended by subsequent acts, clearly outlines the exclusive procedure for enforcing WCC awards. Under this statutory provision, any interested party must file a certified copy of the WCC's final decision in any court of record in the jurisdiction where the accident occurred. This court of record then renders a decree or judgment based on the WCC decision, and it is this court-issued judgment that can be enforced by a writ of execution, in accordance with Section 8, Rule 39, of the Rules of Court. The Court emphasized that the Reorganization Acts did not validly grant the WCC the power to amend Section 51 of the Workmen's Compensation Law, as doing so would unlawfully diminish the jurisdiction and judicial power explicitly vested in the courts of record for issuing and enforcing judgments. Therefore, the power to issue writs of execution remains exclusively with the courts of record, necessitating judicial intervention for the enforcement of WCC awards.
Main Doctrine
The Workmen's Compensation Commission does not possess the power to issue a writ of execution for its awards or decisions; such enforcement must be sought through a court of record by filing a certified copy of the final decision, which then allows the court to render a judgment that can be executed.