G.R. No. L-15521; May 31, 1961
MANILA JOCKEY CLUB, INC., petitioner, vs. N. BAENS DEL ROSARIO, as Associate Commissioner of the Workmen’s Compensation Commission, and BERNARDO S. REYES, respondents.

FACTS

Bernardo S. Reyes, a jockey, filed a claim for compensation under the Workmen’s Compensation Act against the Manila Jockey Club, Inc. He alleged that on March 31, 1957, while riding a horse during a race, he fell and sustained injuries requiring hospitalization and resulting in disability and lost earnings. The petitioner, Manila Jockey Club, controverted the claim, denying an employer-employee relationship. It argued that under the rules of the Games and Amusement Board, a jockey’s sole compensation is a percentage of the prize money paid by the horse owner, not by the racing club.
The hearing officer ruled in favor of Reyes, declaring him an employee of the Club and awarding compensation and medical expenses. The petitioner sought review before the Workmen’s Compensation Commission. Associate Commissioner N. Baens del Rosario rendered a decision modifying the award but still holding the Club liable. The Club then filed a petition for certiorari directly with the Supreme Court to review the Associate Commissioner’s decision.

ISSUE

Whether the petition for certiorari filed by Manila Jockey Club with the Supreme Court is premature for failure to first seek reconsideration of the Associate Commissioner’s decision by the Commission in banc.

RULING

Yes, the petition is premature and must be dismissed. The Supreme Court, citing its precedents in National Shipyards and Steel Corporation vs. Arca, Madrigal Shipping Co., Inc. vs. Del Rosario, and Republic of the Philippines vs. Inciong, established a clear procedural rule. An aggrieved party by a decision of an Associate Commissioner must first seek its reconsideration by the Commission in banc before elevating the case to the Supreme Court. This rule is grounded in the doctrine of exhaustion of administrative remedies, which requires that parties must avail themselves of all administrative processes and appeals within the agency before resorting to judicial review.
The Court clarified that while Section 49 of the Workmen’s Compensation Act outlines the procedure for hearing and determination, the established practice and the Commission’s own rules (Section 3, Rule 24) provide for this review in banc. This step is a prerequisite to judicial recourse. By filing its petition directly with the Supreme Court without first asking the full Commission to reconsider the Associate Commissioner’s decision, the Manila Jockey Club failed to comply with this mandatory procedural sequence. Consequently, the Court dismissed the appeal as prematurely filed, without reaching the substantive issue of the employer-employee relationship. Costs were imposed on the petitioner.