Orbit Transportation Company v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner, Orbit Transportation Company, sought review of a decision and resolution by the respondent Workmen's Compensation Commission. The Commission directed petitioner to pay respondent-claimant, Melecio Crespo (representing his minor grandchild, Rosaline Crespo), P4,360.00 as compensation and burial expenses for the death of a driver-employee, Ramon Crespo. Procedural History: The Workmen's Compensation Commission issued a decision and resolution directing petitioner to pay compensation and burial expenses. The Petition: Petitioner filed a petition for review, claiming it was an error not to consider a P5,000.00 payment as full compensation and to disregard Exhibit 1 (Settlement and Release of Claim) evidencing this payment. Counsel argued that voluntary payment, even if not coursed through the Commission, should be considered valid compensation under Act 3428.
Issue(s)
Whether the petition sufficiently stated the issues and grounds relied upon, considering the facts presented in the annexed decision of the Workmen's Compensation Commission. Whether the suppression of material facts from the petition constitutes a violation of the attorney's oath and rules of pleading.
Ruling
The Court administered a reprimand to the counsels for the petitioner, Attys. Sergio D. Vendero and Renerio R. Bartonico, with a warning that repetition of similar violations would be dealt with severely. Copies of the resolution were ordered to be entered in their personal records and furnished to the Integrated Bar of the Philippines. The petition was denied for lack of merit.
Ratio Decidendi
On the issue of whether the petition sufficiently stated the issues and grounds relied upon, considering the facts presented in the annexed decision of the Workmen's Compensation Commission: The Court found that material facts bearing on the petition's lack of merit had been suppressed by the petitioner's counsel. Specifically, the annexed decision of the Commission revealed that the P5,000.00 claimed as compensation was actually the proceeds of an insurance policy procured by the deceased employee, with premiums paid from his daily income. Furthermore, the claim was uncontroverted. The Court emphasized that annexes do not substitute for allegations of ultimate facts in the pleading itself. The petition's silence on these crucial points, despite their presence in the annexed decision, demonstrated a failure to comply with pleading requirements. The Court cited Cañete vs. Wislizenus for the principle that exhibits do not replace the need for concise and specific allegations of ultimate facts in the complaint or petition. On the issue of whether the suppression of material facts from the petition constitutes a violation of the attorney's oath and rules of pleading: The Court administered a reprimand to the counsels for suppressing material facts. The Court stressed that time pressure is not a justification for the suppression of vital facts that bear on the merit or lack of merit of a petition. Attorneys owe fidelity to the courts and must adhere to Rule 7, Section 5 of the Rules of Court, which states that an attorney's signature certifies that they have read the pleading and believe there is good ground to support it, and it is not interposed for delay. Willful violation of this rule subjects an attorney to disciplinary action. The Court reiterated that the attorney plays a major role in advising clients against pursuing plainly untenable cases, thereby avoiding the clogging of court dockets. The counsels' excuse that the attached copy of the decision made further allegations unnecessary was rejected, as Rule 43, Section 2 requires a concise statement of issues and grounds relied upon, with questions distinctly set forth.
Main Doctrine
Attorneys have a duty of fidelity to the courts and must not suppress material facts bearing on the merit of a petition, even under time pressure, as this violates pleading rules and can lead to disciplinary action.