G.R. No. L-22043; February 28, 1966
AURORA C. MALLARI, for herself and in behalf of her minor children, AVELINO, JOSEFINA, EFREN, and NERISSA, all surnamed MALLARI, plaintiffs-appellees, vs. VICTORY LINER, INC., defendant-appellant.

FACTS

Plaintiff Aurora C. Mallari is the widow of Jose Mallari, a former driver of defendant Victory Liner, Inc. The other plaintiffs are their minor children. Jose Mallari died on September 12-13, 1956, while asleep inside a company bus in San Felipe, Zambales, as required by the defendant, after suffering an attack locally known as “bangungot.” The plaintiffs filed a claim for indemnity under the Workmen’s Compensation Act. On January 23, 1961, a hearing officer of the Workmen’s Compensation Commission (WCC) rendered a decision ordering the defendant to pay the claimants the aggregate sum of P4,000 plus a P5.00 WCC fee. This decision was affirmed on reconsideration by the WCC chairman, who also ordered the defendant to pay an additional P3,000 as attorney’s fees to the claimants and costs for the reconsideration. The defendant’s appeal to the Supreme Court was unsuccessful. Subsequently, on February 5, 1963, the plaintiffs instituted an action in the Court of First Instance of Zambales, praying for judgment in accordance with the WCC decision. On February 14, 1963, the court issued an order rendering judgment for the plaintiffs, ordering the defendant to make specific payments to each plaintiff, pay fees to the WCC, and pay attorney’s fees plus costs.

ISSUE

Whether Section 51 of the Workmen’s Compensation Act is constitutional, specifically whether it infringes on judicial prerogatives and imperils judicial independence by allegedly vesting judicial powers in the Workmen’s Compensation Commission in violation of the principle of separation of powers.

RULING

The Supreme Court found no merit in the defendant’s pretense and affirmed the order of the Court of First Instance of Zambales. The Court held that Section 51 of the Workmen’s Compensation Act does not violate the principle of separation of powers. It noted that under the legal provision, the award of the WCC was appealable to courts of justice. Furthermore, the award, if favorable to the claimant and affirmed on appeal or not appealed, merely provides a cause of action for a judicial decision by a court. It is this judicial judgment, not the administrative award, that is enforced by a writ of execution issued by the court. In this specific case, the WCC award in favor of the plaintiffs had already been upheld by the Supreme Court in a prior case (G.R. No. L-20110). Therefore, the appealed order of the Court of First Instance merely sought to enforce or carry out the decision incorporated therein and the action taken by the Supreme Court in the prior case.