Malabon Restaurant v. Hearing Officer
REITERATIONFacts
The Antecedents: Antonio Datubio filed a claim for compensation against his employers, Malabon Restaurant, for an illness aggravated by his employment as a cook. The employers' counsel requested and was granted an extension to file an answer, but failed to do so. The claimant moved to have the employers declared in default, which was granted after the counsel's explanation for the delay was deemed unsatisfactory. The hearing officer rendered a decision granting compensation. The employers' counsel failed to receive the decision by registered mail, as it was returned unclaimed. Procedural History: The hearing officer issued a certification that the decision had become final and executory due to the employers' failure to appeal. The claimant filed a petition before the Court of First Instance (CFI) of Manila for the rendition of judgment based on the hearing officer's decision, which was granted. The employers then filed a petition for relief from the CFI's decision before the Workmen's Compensation Commission (WCC), which was denied and affirmed by the WCC en banc. A subsequent petition for review before the Supreme Court was dismissed for lack of merit. The Petition: While the claimant was attempting to secure a writ of execution from the CFI, the employers filed the present petition for certiorari, alleging that the hearing officer and the respondent court lacked jurisdiction because the business capital was less than P10,000.00 and the employment was not hazardous or deleterious, thus rendering the decisions null and void.
Issue(s)
Whether the petition for certiorari is barred by res judicata. Whether the claim of lack of jurisdiction based on the business capital and the nature of employment can be raised for the first time in a petition for certiorari to nullify decisions that have become final and executory. Whether the employers' failure to file an answer on time constituted excusable neglect.
Ruling
The petition is denied.
Ratio Decidendi
On the issue of res judicata: The Court held that the grounds alleged in the petition for review previously filed by the petitioners were a reiteration of the grounds set forth in the present petition for certiorari. Both petitions raised exactly the same grounds, seeking to set aside the same decision and its execution. The Court emphasized that a party cannot vary their form of action or adopt a different way of presenting their case to escape the effects of res judicata, as the policy of the law is to put an end to litigation and prevent piecemeal litigation. The Court stated that it will overlook form for substance if its main aim is to forestall delay, which was reflected in the record of the present petition. On the issue of lack of jurisdiction based on capital and hazard: The Court found the petitioners' main claim that the decisions were nullities due to lack of jurisdiction untenable. The Court clarified that such claims could at most serve as a basis for defense and not for the annulment of the decision. The only jurisdictional foundation required for an indemnity under the Workmen's Compensation Act is the existence of an employer-employee relationship. The fact that the employers' income is less than P10,000.00 or that the employment is not hazardous or deleterious are merely affirmative defenses which, if not invoked on time, are deemed waived. On the issue of excusable neglect: Even if the case were considered on its merits, the Court found no recourse but to dismiss it. The petitioners failed to appear before the hearing officer despite notice, and the reasons they provided for their failure were not given credence by the officer. The Court stated that it was not in a position to go into such matters, as questions of this nature are addressed to the sound discretion of the court a quo.
Main Doctrine
A party cannot vary their form of action or adopt a different way of presenting their case to escape the effects of res judicata; the policy of the law is to put an end to litigation and prevent piecemeal litigation. Claims of lack of jurisdiction based on capital or hazard of employment, if not invoked on time, are deemed waived affirmative defenses.