GR L 16538; (October,1961) (Digest)
G.R. No. L-16538. October 27, 1961.
“Y” SHIPPING CORPORATION, petitioner-appellant, vs. AGUSTIN BORCELIS, ET AL., respondents-appellees.
FACTS
Agustin Borcelis filed a claim for compensation against “Y” Shipping Corporation before the Workmen’s Compensation Commission for injuries sustained while employed as a truck driver. The corporation failed to controvert the claim, leading to an award in favor of Borcelis. The corporation’s subsequent petitions for review and reconsideration were denied, and its petition for certiorari to the Supreme Court was dismissed for lack of merit. To enforce the final award, Commissioner Jose Sanchez issued a writ of execution pursuant to Reorganization Plan No. 20-A and the Commission’s rules.
The corporation filed an urgent motion to recall the writ, arguing that the Commission lacked the power to issue it. This motion was denied. The corporation then filed a petition for prohibition before the Court of First Instance of Manila, seeking to nullify the writ. The lower court dismissed the petition, upholding the Commission’s authority under the cited reorganization plan and rules. The corporation appealed this dismissal to the Supreme Court.
ISSUE
Whether the Workmen’s Compensation Commission has the power to issue a writ of execution to enforce its own decisions under Reorganization Plan No. 20-A and its implementing rules.
RULING
No. The Supreme Court reversed the lower court’s order and declared the writ of execution null and void. The Court anchored its ruling on its recent precedent in Pastoral vs. The Commissioners of the Workmen’s Compensation Commission (G.R. No. L-12903, July 31, 1961). The legal logic is clear: Section 51 of the Workmen’s Compensation Act ( Act No. 3428 , as amended) explicitly provided the mechanism for enforcement. A certified copy of the Commission’s final decision must be filed in a court of record, which would then render a judgment based thereon. It is this court-issued judgment, not the Commission’s award, that is enforceable by a writ of execution issued by that court under the Rules of Court.
The power to issue a writ of execution is inherently judicial. An order for execution terminates or destroys a legal right and involves the application of law to specific facts, which is a quintessential judicial function. This function is constitutionally vested in courts. The Reorganization Plan No. 20-A could not validly confer this judicial power upon the Commission, as doing so would amend Section 51 of the Workmen’s Compensation Act and improperly diminish the jurisdiction of courts. Therefore, the Commission’s assumption of such power was an act without legal authority. Consequently, the writ it issued was void.