Community Sawmill Company v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Restituto Mingo claimed compensation against Community Sawmill for disability incurred during his work. The Workmen's Compensation Commission (WCC) awarded Mingo P1,950.71. Procedural History: Petitioner (Community Sawmill) sought to review and set aside the award before the Supreme Court, but its petition was dismissed. Subsequently, Mingo filed a petition in the WCC for a writ of execution, which was issued. The Petition: Petitioner sought to restrain the Provincial Sheriff from levying upon its properties pursuant to the writ of execution issued by the WCC, alleging that the issuance of the writ was null and void for having been done in excess of or without jurisdiction, citing Reorganization Plan No. 20-A.
Issue(s)
Whether the issuance of a writ of execution by the Workmen's Compensation Commission pursuant to Reorganization Plan No. 20-A is null and void for having been done in excess of or without jurisdiction. Whether the enforcement of an award in workmen's compensation cases involves judicial discretion and power granted to courts.
Ruling
The petition for prohibition is granted, and the writ of preliminary injunction restraining the sheriff from enforcing the award of the Workmen's Compensation Commission is declared final. Costs are against Restituto Mingo.
Ratio Decidendi
On the issue of the WCC's jurisdiction to issue a writ of execution: The Court held that the issuance of a writ of execution by the Workmen's Compensation Commission pursuant to Reorganization Plan No. 20-A is null and void as having been done in excess of or without jurisdiction. This is because the enforcement of an award in workmen's compensation cases involves judicial discretion and power granted to the courts under Section 51 of Act No. 3228. Reorganization Plan No. 20-A cannot validly diminish the jurisdiction and judicial power vested in courts of justice. The power to order a writ of execution was not previously held by the WCC before the Reorganization Acts. Such power is essentially judicial, affecting legal rights and potentially terminating them, and is therefore vested in courts or judicial tribunals. The Court reiterated its rulings in previous cases, such as Pastoral vs. The Commissioners of the Workmen's Compensation Commission, which established this principle. Therefore, the WCC acted without jurisdiction in issuing the writ of execution. On the nature of enforcing awards: The Court affirmed that the enforcement of an award in workmen's compensation cases inherently involves judicial discretion and power. This power is explicitly granted to courts of justice by law, specifically Section 51 of Act No. 3228. Reorganization Plan No. 20-A, which sought to grant such enforcement power to the WCC, was deemed an invalid attempt to usurp the judicial functions of the courts. The Court emphasized that powers that are essentially judicial, involving the inquiry into questions of law and fact affecting legal rights, are vested in judicial tribunals. The act of ordering the execution of a decision or award falls squarely within this definition of judicial power. Consequently, the WCC's action in issuing the writ of execution was an overreach of its authority.
Main Doctrine
The enforcement of an award in workmen's compensation cases involves judicial discretion and power granted to courts, which cannot be taken away by Reorganization Plan No. 20-A. Therefore, the Workmen's Compensation Commission cannot issue a writ of execution for such awards.