G.R. Nos. L-17776-04 April 30, 1964
Fortunato F. Halili, petitioner, vs. Rafael Huganas, Juan Gerardo, Workmen’s Compensation Commissioners, Sheriff of Manila and Sheriff of Quezon City, respondents.

FACTS

On May 26, 1958, Rafael Huganas filed a claim for workmen’s compensation against Fortunato F. Halili with Regional Office No. 3 of the Department of Labor. The claim was heard by Hearing Officer Juan Gerardo, who awarded compensation to Huganas. This award was subsequently affirmed upon review by the Workmen’s Compensation Commission. In carrying out the award, the Sheriff of Quezon City initiated execution proceedings.
Consequently, Halili’s counsel filed an action in the Quezon City Court of First Instance to enjoin the execution. Halili contended that the proceedings before the Regional Office and the Commission were null and void, as these bodies derived their authority from Reorganization Plan No. 20-A, which he argued was unconstitutional. The lower court sustained Halili’s position and issued an order enjoining the sheriff from proceeding with the execution. Huganas and the other respondents appealed this decision to the Supreme Court.

ISSUE

The primary issues were: (1) the validity of Reorganization Plan No. 20-A and the proceedings conducted under it, and (2) the authority of the Labor Regional Office to enforce its awards through a writ of execution.

RULING

The Supreme Court affirmed the lower court’s order enjoining the execution, but on a different legal ground, thereby reversing the lower court’s reasoning on the constitutional issue. On the first issue, the Court held that Reorganization Plan No. 20-A was valid concerning claims under the Workmen’s Compensation Act. This ruling was consistent with its prior decisions in Madrigal Shipping Co. vs. Workmen’s Compensation Commission and other cited cases, where the Court had already upheld the Plan’s validity and the official awards made pursuant to it. Therefore, the lower court erred in declaring the proceedings before the administrative agencies null and void based on an unconstitutional delegation of power.
However, the Court affirmed the injunction against the sheriff’s execution on a distinct procedural ground. It reiterated established doctrine that Regional Offices of the Department of Labor, while empowered to adjudicate compensation claims, lack the authority to issue writs of execution for the enforcement of their awards. The power to issue such writs is exclusively vested in courts of justice. Citing precedents like Nations Shipyards vs. Calixto and Pastoral vs. Commissioner of the Workmen’s Compensation Commission, the Court ruled that the execution being carried out by the sheriff pursuant to the Labor Regional Office’s directive was legally infirm. Thus, the lower court’s order preventing the execution was correct in its result, albeit for the wrong reason. No costs were awarded.