GR L 13704; (April, 1962) (Digest)
G.R. No. L-13704; April 18, 1962
BENJAMIN T. ASUNCION, petitioner, vs. LUZ DE ASIS DE AQUINO, respondent.
FACTS
On June 20, 1950, respondent Luz de Asis de Aquino filed a claim for death compensation with the Workmen’s Compensation Division of the Department of Labor against petitioner Benjamin T. Asuncion. Despite summons, Asuncion failed to appear. Subsequently, on May 24, 1951, Aquino filed a complaint for the same compensation with the Court of First Instance (CFI) of Pangasinan, docketed as Civil Case No. 11738. Following the enactment of Republic Act No. 772 on June 20, 1952, which created the Workmen’s Compensation Commission (WCC) and vested it with exclusive jurisdiction over compensation claims, the records from the Workmen’s Compensation Division were transferred to the new Commission. On May 11, 1953, while the CFI case was pending, the WCC acted motu proprio on Aquino’s earlier administrative claim and issued an award. After setting hearings to allow Asuncion to present his defense, which he failed to attend, the WCC issued a final award on January 29, 1955.
ISSUE
Whether the Workmen’s Compensation Commission validly acquired jurisdiction to decide the compensation claim despite the prior filing of a similar action in the Court of First Instance.
RULING
Yes, the Workmen’s Compensation Commission validly exercised jurisdiction. The Supreme Court held that while the CFI initially acquired jurisdiction under the old law ( Act No. 3428 ), Republic Act No. 772 operated to divest the regular courts of jurisdiction over workmen’s compensation claims and transfer exclusive jurisdiction to the WCC. The Court applied the principle that jurisdiction over a pending case may be ousted by the valid repeal of the statute upon which it depends, unless the repealing act contains a saving clause for pending actions. Since Republic Act No. 772 contained no such saving clause, the CFI of Pangasinan was divested of its power to continue with Civil Case No. 11738. Consequently, the WCC acted within its authority in taking cognizance of and deciding the claim. The Court also rejected Asuncion’s claim of denial of due process, finding that the records showed he had been duly notified of the Commission’s hearings but chose not to appear, and only raised the issue nearly a year after the award was issued. The petition for certiorari was denied.