GR L 6359; (December, 1953) (Digest)
G.R. No. L-6359 December 29, 1953
CARMEN CASTRO, ET AL., plaintiffs-appellants, vs. FRANCISCA SAGALES, defendant-appellee.
FACTS
The plaintiffs-appellants filed a complaint for workmen’s compensation in the Court of First Instance of Bulacan in August 1952, arising from the fatal accident that occurred to Dioscoro Cruz (husband of plaintiff Carmen Castro) in January 1952. The defendant-appellee moved for dismissal, and the trial court granted it, holding that jurisdiction over such claims properly belonged to the Workmen’s Compensation Commission. This conclusion was based on Republic Act No. 772 , which took effect on June 20, 1952, and conferred “exclusive jurisdiction” upon the Workmen’s Compensation Commissioner to hear and decide claims under the Workmen’s Compensation Act, subject to appeal to the Supreme Court. Prior to this law, such claims were filed in regular courts.
ISSUE
Whether the Court of First Instance or the Workmen’s Compensation Commission has jurisdiction over a claim for workmen’s compensation arising from an accident that occurred before the effectivity of Republic Act No. 772 (June 20, 1952), but where the complaint was filed after its effectivity (in August 1952).
RULING
The Supreme Court affirmed the order of dismissal, ruling that the Workmen’s Compensation Commission has exclusive jurisdiction. The Court held that while the right to compensation arises from the moment of the accident (January 1952), the declaration or confirmation of that right must be made by the government agency empowered by law at the time the petition is filed. Republic Act No. 772 clearly provides that on and after June 20, 1952, all claims for compensation shall be decided exclusively by the Workmen’s Compensation Commissioner. Since this claim was first formulated in court in August 1952, the Court of First Instance no longer had jurisdiction to act upon it at that time. The application of the law is not retroactive, as it operates upon claims formulated after the law’s approval, not upon accidents that occurred before. The statute pertains to remedy and jurisdiction, which the Legislature has the power to determine, and does not impair vested substantive rights. A litigant does not acquire a vested right to be heard by a particular court before submitting to its jurisdiction.