Corpuz v. The Commanding General
REITERATIONFacts
The Antecedents: Petitioner Eliodora C. Vda. de Corpuz, widow of T/Sgt. Cornelio Corpuz, and her children were awarded P6,000.00 plus P200.00 for burial expenses in a Workmen's Compensation case. The award became final and executory. Procedural History: The respondent Commanding General of the Philippine Army, instead of paying the full award, deducted P3,000.00 representing gratuity paid under Republic Act No. 610 and P250.00 for burial expenses under the Revised Administrative Code, asserting that benefits under RA 610 and the Workmen's Compensation Act are mutually exclusive. Petitioner protested, and the Office of the President, through Acting Assistant Executive Secretary Ronaldo B. Zamora, ruled twice (May 6, 1972, and March 9, 1973) that the deductions were without legal justification and directed full payment. Despite these rulings, the respondent insisted on the deductions, claiming a cause of action for reimbursement to avoid double compensation. This prompted the filing of the instant petition for mandamus. The Petition: Petitioner seeks a writ of mandamus to compel the respondent Commanding General of the Philippine Army to pay the full death compensation benefits awarded to her and her children, which the respondent unlawfully deducted.
Issue(s)
Whether the respondent Commanding General of the Philippine Army acted unlawfully in deducting sums paid under Republic Act No. 610 and Section 699 of the Revised Administrative Code from a final and executory award under the Workmen's Compensation Act. Whether mandamus is the proper remedy to compel the payment of the full award.
Ruling
The writ of mandamus is granted, ordering the respondent Commanding General of the Philippine Army to pay petitioner the sum of P3,250.00 unlawfully deducted from her award of P6,200.00 under the Workmen's Compensation Act.
Ratio Decidendi
On the lawfulness of the deductions: The respondent Commanding General of the Philippine Army acted unlawfully in deducting sums paid under Republic Act No. 610 and Section 699 of the Revised Administrative Code from a final and executory award under the Workmen's Compensation Act. The duty of the officer charged with implementing a final and executory award is purely ministerial, and such an award is not susceptible to change or alteration. The adamant refusal to enforce the award constitutes an unlawful neglect to perform a duty specifically enjoined by law. The respondent's insistence on deducting these amounts from a final award is an unlawful act of excluding the petitioner from the use and enjoyment of a right to which she is legally entitled. The respondent's claim of avoiding double compensation is a matter that should be pursued through proper legal remedies, not by unilaterally altering a final judgment. On the propriety of mandamus: Mandamus is the proper remedy to compel the payment of the full award. The petitioner has a clear, well-defined, and certain right to the enforcement of the entire award because it has become final and executory. It is elementary that once a judgment becomes final and executory, the prevailing party is entitled as a matter of right to a writ of execution. The petitioner had already sought the aid of the Office of the President, which consistently ruled in her favor but failed to convince the respondent to effect full payment. Therefore, there is no other plain, speedy, and adequate remedy in the ordinary course of law than the issuance of the writ of mandamus. The respondent's duty to pay the award is ministerial, and their refusal constitutes unlawful neglect, making mandamus appropriate.
Main Doctrine
A writ of mandamus may be issued to compel the payment of a final and executory award under the Workmen's Compensation Act, even if the claimant has received gratuity under another law, as the respondent's duty to implement the award is ministerial and cannot be altered or reviewed.