G.R. No. L-33149 March 16, 1971
UNITED PHILIPPINE LINES, INC., petitioner, vs. GODOFREDO DEANG, respondent.

FACTS

On January 8, 1969, a Hearing Officer awarded Godofredo Deang P5,886.58 in a workmen’s compensation case against United Philippine Lines, Inc. The employer failed to controvert the claim. The employer later filed a Motion to Set Aside the Award, which was denied by the Referee in an Order dated February 25, 1969. This denial order explicitly stated that any benefits already received by Deang under Section 14 (for temporary total disability) “shall be deducted from the amount of the award.” The employer’s subsequent motions for reconsideration led to the elevation of the records to the Workmen’s Compensation Commission, which ultimately ruled that the original award had become final and executory. A writ of execution was issued, resulting in the garnishment of P5,993.33 from the employer’s bank account.
The employer then filed a Motion to Set Aside the writ of execution, attaching copies of 59 receipts allegedly signed by Deang, showing he had already received P4,249.78 in benefits. The employer argued only P1,636.80 remained due. However, during the hearing on this motion, the Hearing Officer refused to allow the employer to present the original receipts as evidence. The Commission denied the motion to set aside the writ. Notably, the Commission had already authorized the release of P1,636.80 to Deang prior to this denial, retaining the balance of the garnished funds.

ISSUE

Whether the employer was improperly denied the opportunity to prove payments made to the claimant, which should be deducted from the final award pursuant to the Referee’s lawful order.

RULING

The Supreme Court dismissed the petition but without prejudice to the employer’s right to prove the alleged payments. The Court clarified that the Referee’s Order of February 25, 1969, which mandated the deduction of benefits already received from the total award, did not constitute an amendment of the final award. Instead, it was a mere incident in the execution process, a proper implementation of the award. The employer’s substantive right to have such lawful deductions credited was upheld.
Critically, the Court found that the employer was denied procedural due process when the Hearing Officer refused to allow the presentation of the original receipts as evidence. This prevented the employer from substantiating its claim that a significant portion of the award had already been satisfied. Consequently, while the Court dismissed the main petition, it expressly preserved the employer’s rights: (a) to present the 59 receipts either to the Commission or to the Sheriff executing the award, and (b) to have the total amount evidenced by those authentic receipts deducted from the garnished amount. The resolution ensured that execution would conform to the actual amount still due, preventing unjust enrichment.