G.R. No. L-14965. August 31, 1961. DAVID FUENTES, petitioner-appellee, vs. ISABELO V. BINAMIRA, respondent-appellant.
FACTS

David Fuentes filed a petition with the Court of First Instance of Cebu for the execution of a final and executory Workmen’s Compensation Commission decision dated August 23, 1954, awarding him P308.23 for injuries sustained during his employment with respondent Isabelo V. Binamira. The petition included a certification that no appeal was filed within the prescribed period. Binamira opposed the petition, claiming he was never informed of the Commission’s proceedings. He asserted that after receiving a “letter-computation” from the Commission, he wrote a letter contesting liability on the ground that Fuentes was never his employee and submitted a supporting affidavit. He alleged he received no further communication, leading him to believe the case was dismissed. His answer included a cross-petition to declare the award null for violating due process.
The lower court set the case for hearing. Despite notice, Binamira failed to appear on September 5, 1958. The court then rendered judgment confirming the Commission’s award and ordering Binamira to pay. The following day, Binamira filed motions to lift the order of default and for reconsideration, alleging lack of proper notice. The lower court denied these motions, finding notice was duly served and that the Commission’s award was final. Binamira appealed directly to the Supreme Court.

ISSUE

Whether the Court of First Instance erred in rendering a judgment enforcing the final award of the Workmen’s Compensation Commission without conducting a trial on the merits of Binamira’s defenses, particularly his claim of denial of due process.

RULING

No, the Court of First Instance did not err. The appeal is without merit. Section 51 of Act No. 3428, as amended, governs the enforcement of final Workmen’s Compensation Commission awards. It provides that when a certified copy of a final decision is filed in court, “the court shall render a decree or judgment in accordance therewith.” The judgment has the same effect as one rendered in a duly tried case, “except that there shall be no appeal therefrom.” The court’s function is merely ministerial—to enforce the final award, not to alter it or retry the case. The law does not require notification to the adverse party prior to the court’s rendition of such a judgment; it only requires the court to notify the parties after the judgment is rendered.
Binamira’s claim of denial of due process in the Commission’s proceedings is unavailing. The record shows he received the Commission’s initial letter-computation and submitted his opposition and evidence. This constituted substantial compliance with the Act, which allows ex parte evidence reception provided the opposing party is given a chance to rebut. His failure to receive subsequent communications does not invalidate the award, as service is presumed in the ordinary course of mail. Moreover, his proper recourse against any alleged irregularities in the Commission’s proceedings was a timely petition for relief or appeal to the Commission itself, not a collateral attack in the execution proceedings. Since the award had become final and executory, the lower court was legally bound to enforce it summarily. The judgment is affirmed.