GR L 18471; (February, 1963) (Digest)
G.R. No. L-18471; February 28, 1963
NATIONAL SHIPYARDS AND STEEL CORPORATION, plaintiff-appellee, vs. JOSE CALIXTO, The SHERIFF OF THE CITY OF MANILA and The ADMINISTRATOR OF THE REGIONAL OFFICE NO. 3, DEPARTMENT OF LABOR, defendants. JOSE CALIXTO and The SHERIFF OF THE CITY OF MANILA, defendants-appellants.
FACTS
The National Shipyards and Steel Corporation (NASECO) paid two prior compensation awards to its employee, Jose Calixto, as ordered by the Administrator of Regional Office No. 3, Department of Labor, under the Workmen’s Compensation Act. Calixto was subsequently certified by the NASECO medical officer as 100% fit to work. However, the Regional Office later issued a third award for disability compensation totaling P3,096.69. NASECO’s auditor flagged a discrepancy, as the corporation’s medical certification of fitness conflicted with the Regional Office’s finding of a 60% disability. The Regional Administrator demanded payment and, upon non-payment, issued a writ of execution. The Sheriff of Manila levied upon a NASECO vehicle for public auction.
To prevent the sale, NASECO filed a petition in the Court of First Instance of Manila for a writ of preliminary injunction and prohibition. The trial court granted the injunction and later rendered a judgment declaring the Regional Administrator’s award and the writ of execution null and void, making the injunction permanent. Jose Calixto and the Sheriff of Manila appealed the decision.
ISSUE
The core issue is whether the Regional Office No. 3 of the Department of Labor had the judicial authority to adjudicate Calixto’s money claim and the executive power to enforce its award through a writ of execution.
RULING
The Supreme Court affirmed the trial court’s judgment, ruling against the Regional Office’s authority on both counts. The legal logic is grounded in the separation of judicial and executive powers. The Court reiterated its established doctrine that Reorganization Plan No. 20-A, insofar as it conferred judicial power upon the Regional Offices of the Department of Labor to adjudicate and decide money claims of laborers, was null and void. Adjudicating such claims is a judicial function that cannot be vested in an administrative body under the executive department without a constitutional grant.
Consequently, for cases under the Workmen’s Compensation Act, Regional Offices could only act in an investigatory or recommendatory capacity, such as referees submitting reports to the Workmen’s Compensation Commission. It is the Commission that renders the final award. Furthermore, the Court held that even if a valid award existed, the Regional Offices lacked the inherent power to enforce it. The authority to issue writs of execution is a power exclusively vested in courts of justice. Therefore, the Regional Administrator’s award and the subsequent writ of execution he issued were issued without jurisdiction and were correctly declared null and void by the lower court.