City of Davao v. Department of Labor
REITERATIONFacts
The Antecedents: Isaac Abequibil, a laborer in the Office of the City Engineer of Davao, died of pulmonary tuberculosis contracted while in the performance of his duties. While alive, he was granted "allowances" under Section 699 of the Revised Administrative Code. Subsequently, on May 11, 1959, Isaac Abequibil's widow filed a claim against the City of Davao under the Workmen's Compensation Act. Procedural History: The City of Davao objected to the jurisdiction of Regional Office No. 8 of the Department of Labor, contending that Section 699 of the Revised Administrative Code repealed the provisions of the Workmen's Compensation Act and that payment of allowances under the Administrative Code constituted double compensation. Regional Office No. 8 denied the city's motion to dismiss and subsequent motion to vacate. The City of Davao then filed a petition for certiorari with the Court of First Instance of Davao, which was dismissed. The city appealed this dismissal. The Petition: The City of Davao appealed the decision of the Court of First Instance, maintaining its position that the Workmen's Compensation Act was repealed by Section 699 of the Revised Administrative Code and that the Administrative Code should prevail. The city also argued that a hearing is indispensable for claims under the Administrative Code.
Issue(s)
Whether Regional Office No. 8 of the Department of Labor has jurisdiction to adjudicate a claim under the Workmen's Compensation Act involving a city government laborer. Whether the petition for certiorari filed by the City of Davao was the proper procedural vehicle to challenge the Regional Office's denial of its motion to dismiss.
Ruling
The Supreme Court affirmed the decision of the lower court dismissing the petition for certiorari, albeit for different reasons. The Court held that certiorari is not the proper remedy because no question of jurisdiction was involved, and an appeal to the Workmen's Compensation Commission was available. The Court found it unnecessary to pass upon the other issues raised.
Ratio Decidendi
On Issue 1: The Supreme Court affirmed that there is no doubt regarding the jurisdiction of labor regional offices to adjudicate workmen's compensation claims. The Court referenced prior rulings, such as San Miguel Brewery, Inc. v. Sobremesana, La Mallorca v. Ramos, and Madrigal Shipping Co. v. Melad, which consistently sustained this jurisdiction against constitutional challenges to Reorganization Plan 20-A. The City's argument that Section 699 of the Revised Administrative Code (RAC) repealed Section 3 of the Workmen's Compensation Act (WCA) does not automatically negate the jurisdiction of the administrative body specifically tasked with hearing such labor claims. Jurisdiction is conferred by law and is determined by the nature of the claim, which in this case was clearly a workmen's compensation matter. Even if the City believed a different law applied, the Regional Office still possessed the authority to receive the claim and make an initial determination on its merits. Therefore, the City's motion to dismiss based on lack of jurisdiction was correctly denied by the labor regional office. On Issue 2: The Court ruled that the writ of certiorari is intended specifically to keep an inferior court or body within its jurisdiction and may only be used to raise jurisdictional matters or grave abuse of discretion. In the present case, no genuine question of jurisdiction was involved, as the dispute centered on the City's legal theory that one statute repealed another. This represents a question of law regarding the merits of the claim rather than a defect in the authority of the tribunal to hear the case. The Court emphasized that upon the denial of its motion to dismiss, the City's proper course of action was to continue with the proceedings and, if dissatisfied with the result, appeal to the Workmen's Compensation Commission (WCC), which holds exclusive appellate jurisdiction over regional office decisions. Certiorari cannot be utilized as a substitute for the adequate and speedy remedy of appeal that was available to the City. Consequently, the CFI was correct in dismissing the petition for certiorari because the City failed to demonstrate a lack or excess of jurisdiction.
Main Doctrine
A petition for certiorari is not the proper remedy to question the jurisdiction of a labor regional office over workmen's compensation claims when an appeal to the Workmen's Compensation Commission is available. The denial of a motion to dismiss based on alleged repeal of laws does not involve a jurisdictional question but rather an error of law that should be raised on appeal.