Falcon v. Mathay
REITERATIONFacts
The Antecedents: The Workmen’s Compensation Commission (WCC) issued a decision ordering the Republic of the Philippines to pay Modesto Falcon the sum of P3,360.00 for the death of his son, Clarencio T. Falcon, who died in line of duty, plus P336.00 as counsel fees. Procedural History: The Republic, through the Solicitor General, moved to reconsider the award, seeking the deduction of gratuity paid to the claimant under Republic Act No. 610. The WCC denied this motion. The award became final as no appeal was perfected. The Navy Auditor insisted on the deduction, which was supported by the Auditor General. The Petition: Petitioner Antonio Falcon filed a petition for a writ of mandamus to compel the Auditor General to pass in audit and approve for payment the final award of the WCC.
Issue(s)
Whether the Auditor General can insist on deducting a gratuity payment made under Republic Act No. 610 from a final award of the Workmen’s Compensation Commission. Whether the denial of the claimed deduction by the Workmen’s Compensation Commission, having become final, binds the Auditor General.
Ruling
The writ of mandamus is granted. The respondent Auditor General is ordered to pass in audit the petitioner’s claim as decided by the Workmen’s Compensation Commission in its final judgment.
Ratio Decidendi
On the issue of the Auditor General's authority to deduct gratuity payments from a final award: The respondent Auditor General has no alternative but to approve the payment of the Commission’s award. His insistence on reducing the compensation by subtracting the indemnity paid under Republic Act No. 610 amounts to a review of the Commission’s final award. Such review is not authorized by law or jurisprudence. The decisions of the Workmen’s Compensation Commission are exclusively appealable to the Supreme Court, and even this Court is powerless to alter awards that have become final, provided they were made within the Commission's jurisdiction, which is not questioned in this case. The principle of res judicata applies, preventing the re-litigation of issues that have been finally resolved. On whether the finality of the award binds the Auditor General: The denial of the claimed deduction by the Workmen’s Compensation Commission having become final, the respondent Auditor General is bound by it. The respondent in the case before the WCC was the entire Republic of the Philippines, and the Auditor General is not independent of it. Since the finality of the award concludes the Republic, it must also conclude the Respondent Auditor General. The merits of the question raised by him were passed upon and finally resolved in the negative, and it is contrary to justice and public interest to invoke the issue anew. Its denial has become res judicata, meaning a final judgment is conclusive between the parties with respect to the matter directly adjudged or any other matter that could have been raised in relation thereto.
Main Doctrine
The Auditor General cannot insist on reducing a final award of the Workmen's Compensation Commission by deducting therefrom payments made under a separate law, as such action would constitute an unauthorized review of a final judgment, which is conclusive between the parties and has the effect of res judicata.