National Shipyards and Steel Corporation v. Calixto
REITERATIONFacts
The Antecedents: Jose Calixto (claimant) received awards from the Administrator of Regional Office No. 3, Department of Labor, under the Workmen's Compensation Act, totaling P163.64 and P606.42, which the National Shipyards and Steel Corporation (corporation) paid. Subsequently, the Administrator informed the corporation that Calixto was entitled to P760.45 for incapacity and P2,336.26 for non-schedule disability, totaling P3,096.69, minus prior payments. The corporation questioned this award as its medical officer certified Calixto was 100% fit for work, while the Regional Office's medical officer attested to a 60% disability. Procedural History: The Administrator demanded payment of P3,096.69 plus P31 in fees. A writ of execution was issued, leading to the Sheriff of Manila levying upon the corporation's car. The corporation filed a petition for a writ of preliminary injunction and prohibition in the Court of First Instance of Manila. The court issued a preliminary injunction and, after hearing, rendered judgment declaring the award and the writ of execution null and void, making the injunction permanent. The Petition: The claimant and the Sheriff of the City of Manila appealed the decision of the Court of First Instance.
Issue(s)
Whether the Regional Office No. 3 of the Department of Labor was legally created and empowered to hear and decide money claims of laborers. Whether the Regional Office No. 3 has the power and authority to enforce its award by writs of execution.
Ruling
The Supreme Court affirmed the judgment of the Court of First Instance, declaring the award of November 4, 1960, and the execution issued by the Regional Administrator null and void, and making the preliminary injunction permanent. The appeal was dismissed.
Ratio Decidendi
On the issue of the legal creation and power of Regional Office No. 3 to hear money claims: The Court reiterated its previous rulings that Reorganization Plan No. 20-A, insofar as it confers judicial power to Regional Offices of the Department of Labor to adjudicate money claims of laborers, is null and void. In cases falling under the Workmen's Compensation Act, Regional Offices may function as referees, submitting reports to the Workmen's Compensation Commission. The Commission, upon review of these reports, may then render final awards or judgments. On the issue of the power of Regional Office No. 3 to enforce its awards by writs of execution: The Court affirmed the ruling that Regional Offices of the Department of Labor are not empowered to order the execution of their awards through writs of execution. This power is exclusively vested in courts of justice. Therefore, the writ of execution issued by the Regional Administrator was without legal basis and consequently null and void. The Court emphasized that the enforcement of awards must be through the proper judicial channels, not by administrative fiat of a regional office.
Main Doctrine
The Regional Offices of the Department of Labor, as established by Reorganization Plan No. 20-A, are not empowered to adjudicate money claims of laborers or to issue writs of execution to enforce their awards. Such powers are vested exclusively in the courts of justice. Regional Offices may act as referees in cases under the Workmen's Compensation Act, submitting reports to the Workmen's Compensation Commission, which then renders the final award.