Alhambra Cigar & Cigarette Manufacturing Co. v. National Administrator
REITERATIONFacts
The Antecedents: Francisco Atip, a former driver for Alhambra Cigar and Cigarette Manufacturing Co., Inc. (Alhambra), resigned in December 1955, having previously worked as a casual driver in July, August, and September 1957. Atip had notified Alhambra of his sickness, "hypertensive heart disease," as early as July 2, 1954. Alhambra's company physician examined him in July 1955, finding high blood pressure and cardiac enlargement. Alhambra bore the expenses for Atip's confinement and treatment at St. Luke's Hospital from July 5-11, 1955, and September 29-October 6, 1955. Procedural History: On October 22, 1959, Atip filed a claim for compensation under the Workmen's Compensation Act with Regional Office No. 2 of the Department of Labor in Tuguegarao, Cagayan, for an illness of "rheumatism leading to paralysis" contracted in 1954. Alhambra moved to dismiss the claim, asserting it was barred by the statute of limitations, but Atip opposed this motion. The Hearing Officer, Eugenio Caleda, denied the motion to dismiss on August 26, 1960, reasoning that medical treatment provided by Alhambra obviated the need for formal notice. Alhambra's motion for reconsideration was also denied. The Petition: On January 11, 1961, Alhambra filed a petition for certiorari, prohibition, and preliminary injunction with the Court of First Instance (CFI) of Manila, seeking to prevent the Regional Labor Administrator and Hearing Officer from proceeding with Atip's claim. The CFI of Manila issued a preliminary injunction ex parte on January 13, 1961. The respondents moved to dismiss, arguing it failed to state a cause of action and that the claim was not barred, but these motions were denied. The CFI of Manila, on September 20, 1962, granted the petition, permanently enjoining the labor officials and Atip from proceeding with the claim, leading the labor officials to appeal this decision.
Issue(s)
Whether the Court of First Instance of Manila had jurisdiction to issue a writ of certiorari and prohibition with preliminary injunction against officers of the Department of Labor's Regional Office No. 2 located in Tuguegarao, Cagayan. Whether the Regional Office of the Department of Labor has original and exclusive jurisdiction over cases falling under the Workmen's Compensation Law. Whether the Hearing Officer acted in excess of jurisdiction or with grave abuse of discretion in denying the motion to dismiss and proceeding with the hearing of Atip's claim.
Ruling
The decision of the Court of First Instance of Manila is reversed. The writ of certiorari, prohibition, and injunction issued by the lower court are declared null and void, cancelled, and rendered without force and effect. The respondents-appellants are declared with authority to proceed with the hearing and to decide the claim of Francisco Atip.
Ratio Decidendi
On the jurisdiction of the Court of First Instance to issue writs against officers outside its territorial jurisdiction: The Supreme Court held that the Court of First Instance of Manila erred in taking cognizance of the petition for certiorari and prohibition. The Court reiterated the principle that the jurisdiction of courts of first instance to issue writs of injunction, certiorari, and prohibition is limited to acts committed or to be committed within their respective provinces and districts. Citing Section 4, Rule 67 of the old Rules of Court (now Section 4, Rule 65), the Court emphasized that the petition must be filed in a Court of First Instance having jurisdiction over the corporation, board, officer, or person whose acts are in question. Since the Regional Office and its officers were located in Tuguegarao, Cagayan, the Court of First Instance of Manila, which belongs to a different judicial district, lacked the territorial jurisdiction to issue the said writs against them. The Court found merit in the contention of the respondents-appellants that the court below had no jurisdiction to take cognizance of the petition because the acts complained of were not performed within Manila or its judicial district. On the original and exclusive jurisdiction of the Regional Office: The Court affirmed that under Section 25, Article VI of Reorganization Plan No. 20-A of the Department of Labor, each Regional Office has original and exclusive jurisdiction over all cases falling under the Workmen's Compensation Law. This jurisdiction includes the power to entertain claims filed under the said law. Therefore, the Regional Office, through its hearing officer, acted within its granted powers when it entertained Atip's claim. The Court noted that the issue of whether the claim was barred by the statute of limitations was a matter for the competent authority, the hearing officer, to determine, and any adverse decision could be appealed to the Workmen's Compensation Commission. On whether the Hearing Officer acted in excess of jurisdiction or with grave abuse of discretion: The Supreme Court clarified that the Hearing Officer did not act in excess of jurisdiction or with grave abuse of discretion. The term "excess of jurisdiction" implies that a tribunal has jurisdiction but oversteps it, while "grave abuse of discretion" refers to a capricious and whimsical exercise of judgment equivalent to lack of jurisdiction. The issue of whether Atip's claim was barred by the statute of limitations was within the competence of the Hearing Officer to resolve. If the Hearing Officer found that the claim was filed within the time allowed by law, such a finding was within the scope of his jurisdiction. Any error in this determination would be an error of judgment, correctible by appeal, not by a writ of certiorari. Since Alhambra did not appeal the Hearing Officer's order but instead filed a petition for certiorari and prohibition in the wrong court, the CFI of Manila should not have entertained the petition.
Main Doctrine
A Court of First Instance lacks jurisdiction to issue writs of certiorari, prohibition, and injunction against officers of a Regional Office of the Department of Labor located outside its territorial jurisdiction, as such writs are limited to acts committed or to be committed within the court's province or district.