Divinagracia v. Court of First Instance
REITERATIONFacts
1. The Antecedents: Manuel Divinagracia, a carpenter, suffered an accident on February 28, 1957, while working in a furniture manufacturing shop operated by respondent Don Bosco Technical Institute, Inc. The accident resulted in the loss of use of one eye, with a risk to the other. Divinagracia filed a claim for compensation. 2. Procedural History: Regional Office No. 3 of the Department of Labor awarded Divinagracia P2,909.27 in compensation and expenses. This award was affirmed by the Chairman of the Workmen's Compensation Commission and subsequently by the Commission en banc. The Institute appealed to the Supreme Court (G.R. No. L-16500), which dismissed the petition for being factual and without merit. The Commission then issued a writ of execution. Subsequently, the Institute filed Civil Case No. 43192 in the Court of First Instance of Manila to annul the Commission's decision and writ of execution, arguing the Commission lacked jurisdiction. The Court of First Instance issued a preliminary injunction in this case. 3. The Petition: Manuel Divinagracia initiated the present original action for prohibition and injunction, seeking to restrain the Court of First Instance of Manila from proceeding with Civil Case No. 43192 and to annul the preliminary injunction issued therein. Divinagracia contends that the Court of First Instance exceeded its jurisdiction by suspending the execution of a final and executory decision of the Workmen's Compensation Commission. The petition argues that the issue of the Commission's jurisdiction over the Institute, based on its non-profit status, was already decided in G.R. No. L-16500 and is now res judicata. However, the petition also acknowledges that the writ of execution itself was void as the power to issue such writs is judicial and cannot be vested in administrative bodies like the Commission.
Issue(s)
Whether the alleged lack of jurisdiction of the Workmen's Compensation Commission, having been raised and rejected at all levels, including the Supreme Court, constituted res adjudicata. Whether the Workmen's Compensation Commission possessed the authority to issue a writ of execution for its own final and executory award.
Ruling
The petition is dismissed, and the writ of preliminary injunction issued in the present case is dissolved. The Court of First Instance of Manila did not err in taking cognizance of Civil Case No. 43192 and issuing the writ of preliminary injunction.
Ratio Decidendi
On Issue 1: The Supreme Court held that the alleged lack of jurisdiction of the Workmen's Compensation Commission (Commission) was indeed res adjudicata. The Institute had consistently invoked this argument throughout the administrative proceedings and even in its certiorari appeal to the Supreme Court in G.R. No. L-16500. The Commission's finding that the shop was operated for profit, which was the basis for asserting jurisdiction, was explicitly assailed in the Institute's petition for certiorari and motions for reconsideration before the Supreme Court. The Supreme Court's dismissal of that petition for lack of merit and subsequent denial of reconsideration rendered the jurisdictional issue, and all underlying findings, conclusive as between Divinagracia and the Institute. Therefore, the CFI Manila could not validly revisit the issue of the Commission's jurisdiction to entertain Divinagracia's compensation claim. On Issue 2: The Supreme Court ruled that the disputed writ of execution issued by the Workmen's Compensation Commission was null and void, because the power to issue such a writ is judicial in nature and cannot be vested in administrative bodies. Section 51 of the Workmen's Compensation Act explicitly outlines the procedure for enforcing awards: any party in interest must file a certified copy of the decision with a court of record, which then renders a decree or judgment and issues the corresponding writ of execution. This procedure confirms that the power of execution rests solely with the courts, not the Commission. The Court reiterated its view from Pastoral vs. The Commissioners of the Workmen's Compensation Commission and Community Sawmill Co. vs. The Workmen's Compensation Commission, et al., emphasizing that functions affecting legal rights and resulting in their termination are essentially judicial powers. For this reason, the CFI Manila did not err in taking cognizance of Civil Case No. 43192 and in issuing the writ of preliminary injunction, but only to address the nullity of the administrative body's writ of execution.
Main Doctrine
The power to issue a writ of execution is judicial in nature and cannot be vested in administrative bodies. Once a decision has become final and executory, and the issue of jurisdiction has been passed upon and affirmed by the Supreme Court, it becomes res adjudicata and no longer subject to review by any court.