Syjuco, Inc. v. Resultan
REITERATIONFacts
The Antecedents: Justo Resultan, a salesman of appellant company Santiago Syjuco, Inc., died in April 1958. His widow, Felisa Resultan, filed a claim for death benefits under the Workmen's Compensation Law. Appellant did not controvert the claim. Procedural History: On July 29, 1958, the Workmen's Compensation Commissioner issued an award for P4,000.00 as death compensation and P200.00 as burial expenses, plus legal fees. The award became final and executory on September 15, 1959. On October 1, 1958, the Commission issued a writ of execution, leading to the garnishment of appellant's funds in the Philippine Bank of Commerce. The present action was commenced by appellant to enjoin the enforcement of the writ. The trial court dismissed the complaint and dissolved the preliminary injunction. The Petition: Plaintiff appeals the dismissal of its complaint, raising two issues: (1) whether the Workmen's Compensation Commission can make an award in lump sum instead of installments, and (2) whether it can issue a writ of execution.
Issue(s)
Whether the Workmen's Compensation Commission is authorized by law to make an award for the payment of death benefits in lump sum instead of by installments. Whether the Workmen's Compensation Commission can issue a writ of execution for the enforcement of its award.
Ruling
The judgment appealed from is reversed; the writ of execution issued by appellee Workmen's Compensation Commission, together with all proceedings in connection therewith, is vacated; and appellees are permanently enjoined from enforcing the same. No costs.
Ratio Decidendi
On the issue of lump sum award vs. installments: The Court noted that the award did not specify payment by installments. In the absence of such specification, it should be understood as payable in lump sum. Furthermore, even if the award should have been paid in installments, the period for such payment (208 weeks) had already expired since the liability attached in April 1958, rendering the issue moot. The authority of the Commission to settle and adjudicate the claim and the correctness of the amount were admitted. On the authority of the Commission to issue a writ of execution: The Court reiterated its previous rulings that Section 12, Article III of Reorganization Plan No. 20-A, which vested the Commission with the power to order execution, was declared void and unconstitutional. The Commission has no inherent power to order the execution of its decisions. Such awards must be enforced in accordance with Section 51 of the Workmen's Compensation Law, which requires filing a certified copy of the award in a court of record, which court shall then render a decree or judgment in accordance therewith. The Court expressed disappointment with the appellant's resort to technicalities to delay payment of a just claim.
Main Doctrine
The Workmen's Compensation Commission does not have the inherent power to issue a writ of execution to enforce its awards; such awards must be enforced through the regular courts as provided by Section 51 of the Workmen's Compensation Law.