GR L 17914; (October, 1962) (Digest)
G.R. No. L-17914; October 31, 1962
ROSARIO MARTIN VDA. DE MALLARI, plaintiff-appellant, vs. NATIONAL DEVELOPMENT COMPANY, defendant-appellee.
FACTS
Rosario Martin Vda. de Mallari filed a claim with the Workmen’s Compensation Commission for death benefits following the demise of her daughter, Milagros Mallari, a spare weaver for the National Development Company (NDC). She alleged that due to the nature of her work and an accident in March 1951, Milagros contracted pulmonary tuberculosis, leading to her retirement in September 1951 and her death on July 12, 1953. This administrative claim was withdrawn before adjudication.
Subsequently, the appellant filed a civil action in the Court of First Instance of Manila, seeking recovery under Article 1711 of the New Civil Code. Her complaint posited that the claim was not covered by the Workmen’s Compensation Act because her daughter died more than one year after contracting the disease, thus purportedly falling outside the Act’s scope and allowing a civil code action. The lower court dismissed the complaint for lack of cause of action and lack of jurisdiction.
ISSUE
Whether the Court of First Instance had jurisdiction over the appellant’s claim for death compensation, or whether such claim fell under the exclusive jurisdiction of the Workmen’s Compensation Commission.
RULING
The Supreme Court affirmed the dismissal, holding that the lower court correctly ruled it lacked jurisdiction. The legal logic is anchored on the exclusive jurisdiction conferred by statute and the applicability of the Workmen’s Compensation Act to the claim’s factual allegations. Republic Act No. 772 , amending the Workmen’s Compensation Act, grants the Workmen’s Compensation Commissioner original and exclusive jurisdiction over all compensation claims, with appeals directly to the Supreme Court. This exclusive jurisdiction applies to all claims filed on or after June 20, 1952, regardless of whether the accident occurred before that date.
Critically, the Court examined the facts as alleged in the complaint. It found that Milagros Mallari contracted the disease in September 1951 and died on July 12, 1953—a period clearly within two years from the date of sickness. Section 7 of Republic Act 772 expressly provides that if death occurs within two years from the date of injury or sickness, compensation is due. Therefore, the claim was squarely covered by the Workmen’s Compensation Act, not the Civil Code. Since the Act provides the exclusive remedy, jurisdiction lies solely with the administrative commission. The Court emphasized the legislative intent to centralize the investigation and adjudication of all workmen’s compensation claims within the Commission. The dismissal was without prejudice to the appellant’s right to refile her claim with the proper agency, the Workmen’s Compensation Commission.