G.R. No. L-17502. May 30, 1962.
A. V. H. & COMPANY OF THE PHILIPPINES, petitioner, vs. WORKMEN’S COMPENSATION COMMISSIONER, MARIANO B. ALUMNO, SHERIFF OF MANILA and SHERIFF OF PASAY CITY, respondents.

FACTS

Respondent Mariano B. Alumno filed a workmen’s compensation claim against petitioner A.V.H. & Company for injuries sustained while working. After administrative proceedings, the Workmen’s Compensation Commission rendered a decision on June 22, 1960, ordering the Company to pay Alumno P849.09. The Company did not appeal this decision. Subsequently, the Commission issued writs of execution to the Sheriffs of Manila and Pasay City to enforce the monetary award.
The Company then filed a petition for prohibition with the Court of First Instance of Manila, seeking to annul the Commission’s decision and the writs of execution. It argued that Act No. 3428 (the Workmen’s Compensation Act) was unconstitutional for delegating judicial powers to an administrative body and that only courts could issue writs of execution. The lower court dismissed the petition, ruling it was insufficient in form and substance because the Company had neither appealed the Commission’s decision nor questioned its jurisdiction beforehand. The Company appealed to the Supreme Court.

ISSUE

The primary issue is whether the Workmen’s Compensation Commission had the authority to issue writs of execution for the enforcement of its decisions.

RULING

The Supreme Court set aside the lower court’s order and declared the writs of execution null and void. The Court clarified the statutory enforcement mechanism under the Workmen’s Compensation Act. Section 51 of Act No. 3428 provides that if an employer fails to comply with the Commission’s decision, a certified copy of that decision shall be filed with the proper Court of First Instance. The court shall then render a judgment in accordance with the decision, and it is this court judgment, not the administrative decision itself, that is enforceable by a writ of execution. Therefore, the Act does not authorize the Commission to issue an “enforceable” decision in the sense of directly issuing a writ of execution.
Furthermore, the Court reaffirmed its prior rulings in Everlasting Pictures, Inc. v. Fuentes and Pastoral v. Workmen’s Compensation Commission, declaring that the provision in Reorganization Plan No. 20-A which authorized the Commission to issue writs of execution was unconstitutional. Consequently, the writs issued in this case were issued without legal authority. While the Company failed to follow proper procedure for a writ of prohibition, the Supreme Court held that the patent nullity of the writs justified intervention to prevent their enforcement, overriding purely procedural objections. The preliminary injunction was made permanent.