Philippine Rabbit Bus Lines v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: The underlying dispute originated from a claim for compensation filed by Ildefonso Rodumban against Philippine Rabbit Bus Lines, Inc. Rodumban alleged that while in the employ of the bus company, he suffered an accident resulting in the loss of sight in both eyes. The company controverted the claim, asserting that the loss of sight was due to a venereal disease. Procedural History: The chief hearing officer of the Manila Regional Office initially ruled in favor of Rodumban, ordering the bus company to pay compensation and fees. Following the denial of a motion for reconsideration, the case was elevated to the Workmen's Compensation Commission. The Commission allegedly rendered a decision affirming the initial ruling and ordering additional payments. Subsequently, Rodumban filed a petition for execution of this decision in the Court of First Instance of Tarlac. The bus company contested the execution, arguing that it had not received due notice of the Commission's decision and that its finality was disputed. The Court of First Instance, despite the ongoing dispute regarding notice and finality, proceeded with the execution proceedings, including the issuance of a writ of execution and the levy on one of the company's buses. The Petition: Philippine Rabbit Bus Lines, Inc. filed two petitions for certiorari with the Supreme Court. The first petition (G.R. No. L-20614) challenged the Workmen's Compensation Commission's order denying the company's motion to declare void the alleged service of notice of judgment, arguing grave abuse of discretion. The second petition (G.R. No. L-21577) challenged the Court of First Instance of Tarlac's actions in proceeding with the execution of the Commission's decision despite the pending dispute over notice and finality, also alleging excess of jurisdiction or grave abuse of discretion. The company sought to have these orders declared void and to prevent the execution of the compensation award.
Issue(s)
Whether the WCC acted with grave abuse of discretion in denying PRBLI's motion to declare the service of notice of judgment void and in declaring its decision final and executory. Whether the CFI of Tarlac acted in excess of jurisdiction or with grave abuse of discretion in proceeding with the execution of the WCC decision despite the pendency of a certiorari case before the Supreme Court questioning the executory nature of the WCC decision.
Ruling
The petitions are dismissed, and the writs prayed for are denied.
Ratio Decidendi
On Issue 1: The Court held that the WCC's order denying PRBLI's motion to declare the service of notice of judgment void was analogous to a denial of a petition for relief from a final judgment, making it final and appealable. Therefore, certiorari under Rule 65 was not the proper remedy. Even if it were, the Court found no grave abuse of discretion. The WCC found that the signature on the notice was that of "someone in the office of respondent's counsel" and that the person who signed knew what they were doing by affixing the date of receipt. The Court upheld the presumption that official duty was regularly performed, which PRBLI failed to successfully assail. Thus, any error in the WCC's conclusion was merely an error of judgment, not a grave abuse of discretion. On Issue 2: The Court found it unnecessary to rule on the second petition (G.R. No. L-21577) because its resolution depended on the outcome of the first petition (G.R. No. L-20614). Since the Court dismissed the first petition, the proceedings in the CFI, including the issuance of the writ of execution, were deemed proper and in accordance with law, assuming the WCC decision had indeed become final and executory. The existence of a prejudicial question pending before the Supreme Court was considered to have merely academic value in this context.
Main Doctrine
The Supreme Court reiterated that a petition for certiorari under Rule 65 of the Rules of Court is not a substitute for an appeal. An order denying a motion to declare void the service of notice of judgment is considered final and appealable, not subject to review by certiorari unless there is a showing of grave abuse of discretion. Furthermore, the Court emphasized the presumption of regularity in the performance of official duty, holding that the Commission's findings, even if potentially erroneous, did not constitute grave abuse of discretion if they were mere errors of judgment.