Asuncion v. Aquino
REITERATIONFacts
The Antecedents: On June 20, 1950, Luz de Asis de Aquino filed a claim for compensation against Benjamin T. Asuncion for the death of her husband with the Workmen's Compensation Division of the Department of Labor. Asuncion failed to appear despite repeated summons. Procedural History: On June 20, 1952, Republic Act No. 772 was enacted, transferring all pending compensation claims to the newly created Workmen's Compensation Commission. Prior to this, on May 24, 1951, Aquino had also filed a complaint for the same compensation with the Court of First Instance of Pangasinan. On May 11, 1953, the Workmen's Compensation Commission motu proprio awarded compensation to Aquino based on the existing records. Asuncion disclaimed liability and failed to appear at two subsequent hearings set by the Commission to allow him to prove his defense. Consequently, on January 29, 1955, the Commission issued another award. Asuncion received this award on March 28, 1955. The Petition: Asuncion filed a motion for reconsideration on April 5, 1955, alleging lack of jurisdiction by the Commission due to a pending claim in the Court of First Instance and denial of his day in court due to lack of proper notification. The motion was denied, leading Asuncion to file the present petition for certiorari before the Supreme Court, arguing that the Court of First Instance had already acquired jurisdiction and that the enactment of Republic Act No. 772 did not divest it of such jurisdiction, and that he was not given his day in court.
Issue(s)
Whether the Workmen's Compensation Commission acquired jurisdiction over the claim despite a pending case in the Court of First Instance and the enactment of Republic Act No. 772. Whether petitioner Benjamin T. Asuncion was denied his day in court.
Ruling
The petition is denied. The award of the respondent Workmen's Compensation Commission dated January 29, 1955, is affirmed. No costs.
Ratio Decidendi
On Whether the Workmen's Compensation Commission acquired jurisdiction over the claim despite a pending case in the Court of First Instance and the enactment of Republic Act No. 772: The Supreme Court held that the contention is without merit. While regular courts had jurisdiction under Act No. 3428, the enactment of Republic Act No. 772 divested them of such jurisdiction, transferring it exclusively to the Workmen's Compensation Commission. Even if the claim was already filed with the Court of First Instance before Republic Act No. 772, the court was divested of its power to hear and decide it upon the enactment of the new law, as there was no saving clause preserving pending actions. Therefore, the Workmen's Compensation Commission acted properly when it took cognizance of and decided the claim, as the proper forum for claims accruing before June 20, 1952, but formulated thereafter, is the Workmen's Compensation Commission. On Whether petitioner Benjamin T. Asuncion was denied his day in court: The Supreme Court found this contention to be of no avail. The records showed that petitioner was duly notified of two hearings set by the Commission. While the first notice's delivery status was unclear, the second notice was confirmed to have been delivered and received by the petitioner. Despite receiving the award on March 28, 1955, petitioner only filed his motion for reconsideration on April 5, 1955, raising the issue of late receipt of the hearing notice for the first time. This delay, nearly one year after the hearing, indicated that he kept silent and thus could not now complain of being deprived of his day in court.
Main Doctrine
The enactment of Republic Act No. 772, which vested exclusive jurisdiction over workmen's compensation claims in the Workmen's Compensation Commission, divested regular courts of their previously held jurisdiction over such matters. This divestment applies even to claims that were already pending before the regular courts at the time of the enactment, provided there is no saving clause in the new law preserving the jurisdiction of the regular courts over pending actions. Furthermore, a party who fails to appear at hearings despite proper notice, and does not promptly move for reconsideration upon receiving an adverse award, may be deemed to have waived their right to be heard.