G.R. No. L-18730. September 16, 1961. SAN MIGUEL BREWERY, INC., petitioner, vs. REGINO SOBREMESANA and WORKMEN’S COMPENSATION COMMISSION, respondents.
FACTS

Regino Sobremesana, a truck driver for San Miguel Brewery, Inc., filed a claim for workmen’s compensation on June 23, 1959, with Regional Office No. 4 of the Department of Labor, alleging his pulmonary tuberculosis was aggravated by his employment conditions. The company contested the claim, arguing it was not compensable and had prescribed. The hearing officer rendered a decision on October 25, 1960, finding the illness compensable and ordering the company to pay disability benefits.
San Miguel Brewery moved for reconsideration and, upon denial, appealed to the Workmen’s Compensation Commission, which affirmed the hearing officer’s decision. The company then petitioned the Supreme Court for certiorari, raising two primary grounds: first, that the hearing officer and the Commission lacked jurisdiction because their authority under Reorganization Plan No. 20-A had been declared null and void in previous cases; and second, that the factual findings supporting the compensation award lacked substantial evidence.

ISSUE

The core issues were: (1) whether the Regional Office and the Workmen’s Compensation Commission validly exercised jurisdiction over the claim under Reorganization Plan No. 20-A, and (2) whether the award was supported by sufficient evidence.

RULING

The Supreme Court dismissed the petition, ruling it lacked merit. On the jurisdictional challenge, the Court clarified its prior rulings. It held that its decisions in Corominas and related cases did not nullify Plan 20-A concerning workmen’s compensation claims. Citing Miller vs. Mardo, the Court explicitly stated that Plan 20-A was invalid only insofar as it conferred judicial power on Regional Offices over cases other than those under the Workmen’s Compensation Law. The adjudication of such claims was a power already exercised by the Department of Labor’s Compensation Commission even before reorganization.
Section 25 of Plan 20-A merely reallocated this existing departmental power to hearing officers in Regional Offices, conforming to the authority granted by Republic Act No. 997 , as amended. Thus, there was no assumption of new judicial powers, and the jurisdictional grant was valid. The Court distinguished its holding in Pastoral vs. Workmen’s Compensation Commission, which concerned the Commission’s lack of power to issue writs of execution—a power originally vested in courts of record and not transferable via executive reorganization.
On the substantive issue, the Court found the compensation award was supported by adequate evidence. It emphasized the statutory presumption of compensability under Section 44 of the Workmen’s Compensation Act (No. 3428), as amended, which operates in favor of the claimant. Reviewing the proofs, the Court upheld the factual findings of the Commission. Consequently, the petition was dismissed.