Layag v. Gerardo
REITERATIONFacts
The Antecedents: Remedios Layag, et al., presented a complaint with the Department of Labor, Regional Office No. 3, Manila, for disability benefits as heirs of Alberto Layag, who died while employed with the Section of Floating Equipment, Division of Ports and Harbors, Bureau of Public Works. The Republic, through the Solicitor General, controverted the claim, asserting lack of cause of action due to no allegation that the death was directly caused by employment. Procedural History: Respondent hearing officer Juan Gerardo rendered a decision finding the death compensable and ordering the Republic to pay P4,000.00 in death compensation benefits and P200.00 for burial expenses. The Republic moved for an extension to file a motion for reconsideration, which was granted by the Hearing Officer. Petitioners' counsel moved to reconsider the order granting the extension, alleging non-compliance with rules on service. The Hearing Officer denied this motion. Subsequently, the Hearing Officer ordered the elevation of the entire record to the Workmen's Compensation Commission. Alleging grave abuse of discretion and denial of due process, petitioners filed a petition for a Writ of Certiorari with the CFI of Manila. The CFI dismissed the petition, citing lack of jurisdiction, as the Workmen's Compensation Commission or its Commissioner is not an "inferior court" or "officer or person" within the meaning of Section 4, Rule 67 of the Rules of Court, and that the CFI is not a "superior court" in contemplation of the definition of certiorari. The Petition: Petitioners appealed the CFI's dismissal of their petition for certiorari, arguing that the CFI erred in dismissing the petition for lack of jurisdiction and in not granting the petition.
Issue(s)
Whether the Court of First Instance has jurisdiction to issue a writ of certiorari against orders of the Regional Hearing Officer of the Department of Labor (Workmen's Compensation Commission). Whether the orders of the Hearing Officer granting an extension and denying a motion for reconsideration constituted grave abuse of discretion or denial of due process.
Ruling
The Supreme Court affirmed the Order of the Court of First Instance dismissing the petition for writ of certiorari. The Court held that the CFI had no jurisdiction over the subject matter of the petition.
Ratio Decidendi
On the jurisdiction of the CFI to issue a writ of certiorari: The Supreme Court reiterated that the Workmen's Compensation Act vests exclusive jurisdiction in the Workmen's Compensation Commission (WCC) to hear and decide compensation claims, with decisions appealable to the Supreme Court. Reorganization Plan 20-A further transferred powers to the Commission and its Regional Offices, granting them original and exclusive jurisdiction over cases under the Workmen's Compensation Law. The Court emphasized that the WCC or its Commissioner is not an "inferior court" or an "officer or person" within the meaning of Section 4, Rule 67 of the Rules of Court, which governs petitions for certiorari. Consequently, a Court of First Instance, not being a "superior court" in this context, lacks the authority to issue a writ of certiorari against the WCC or its officers. The proper remedy for aggrieved parties is to appeal to the WCC and subsequently to the Supreme Court. On whether certiorari was proper even if jurisdiction existed: The Court further opined that even if the CFI had jurisdiction, certiorari would not lie. The granting of extensions for filing motions for reconsideration are interlocutory orders and fall within the sound discretion of the Commission. In this case, the extension granted did not prejudice the petitioner's rights. Moreover, any error in granting the extension would constitute a mistake of law or fact, which is correctible by appeal, not by certiorari, unless it amounts to grave abuse of discretion. The Court cited Villa-Rey Transit, Inc. v. E. Bello, et al., stating that if a court, board, or person has jurisdiction over the subject matter and the parties, its orders or decisions, however irregular or erroneous, cannot be corrected by certiorari but by appeal.
Main Doctrine
The Court of First Instance has no jurisdiction to issue a writ of certiorari against orders of the Workmen's Compensation Commission or its Hearing Officers, as these are not considered inferior courts or officers within the contemplation of the Rules of Court for certiorari purposes. Appeals from decisions of the Workmen's Compensation Commission should follow the prescribed appellate procedure.