G.R. No. L-44077. September 30, 1978
ELIODORA C. VDA. DE CORPUZ, petitioner, vs. THE COMMANDING GENERAL, PHILIPPINE ARMY, respondent.

FACTS

Petitioner Eliodora C. Vda. de Corpuz is the widow of T/Sgt. Cornelio Corpuz. Acting Referee Claro Q. Riego de Dios of the Workmen’s Compensation Unit awarded her and her children P6,000.00 as death compensation plus P200.00 for burial expenses due to the service-connected death of her husband. This award in WC Case No. R04-13114 became final and executory. The Solicitor General indorsed the award to the respondent Commanding General of the Philippine Army for payment.
However, the respondent’s office prepared a voucher for only P2,950.00, deducting P3,250.00 from the total award. This deduction represented P3,000.00 paid as a gratuity under Republic Act No. 610 (the Armed Forces Death Gratuity and Disability Pension Act) and P250.00 for burial expenses under the Revised Administrative Code. The respondent insisted these benefits were mutually exclusive with Workmen’s Compensation benefits, justifying the deduction to prevent double compensation. Despite two separate decisions from the Office of the President (OP Decision No. 19, s. 1972 and OP Decision No. 168, s. 1973) which ruled the deduction was without legal justification and ordered full payment, the respondent refused to comply, prompting the petitioner to file this petition for mandamus.

ISSUE

Whether a writ of mandamus may be issued to compel the respondent Commanding General to pay the full amount of a final and executory Workmen’s Compensation award, despite deductions made for other benefits received by the claimant.

RULING

Yes, the Supreme Court granted the writ of mandamus. The legal logic is clear and rests on the nature of a final and executory judgment. The Workmen’s Compensation award had attained finality, meaning it was no longer subject to appeal, review, or alteration. The respondent’s duty to disburse the full awarded amount was therefore purely ministerial; it involved no discretion to recalculate, deduct, or reinterpret the award. By insisting on the deductions, the respondent unlawfully excluded the petitioner from enjoying a vested right and neglected a duty specifically enjoined by the final judgment.
The Court rejected the respondent’s argument against “double compensation.” While the law may prohibit simultaneous recovery under different statutes, the proper remedy for the government to recover alleged overpayments is a separate civil action for reimbursement, not a unilateral deduction from a final award. The respondent’s act of withholding payment effectively constituted an unauthorized review of the Workmen’s Compensation Commission’s final decision, which is not permitted by law. The Court cited the precedent of Falcon v. Mathay, which similarly compelled payment of a final compensation award. Since the petitioner had no other plain, speedy, and adequate remedy—having already secured favorable rulings from the Office of the President to no avail—mandamus was the appropriate remedy to enforce a clear legal right. The Court ordered the respondent to pay the unlawfully deducted sum of P3,250.00.