G.R. No. L-8379; April 24, 1956
VICTORINO MANALO, plaintiff-appellant, vs. FOSTER WHEELER CORPORATION AND CAPITAL INSURANCE AND SURETY COMPANY, INC, defendants-appellees.

FACTS

The plaintiff-appellant, Victorino Manalo, filed a complaint in the Batangas Court of First Instance against his employer, Foster Wheeler Corporation, and its insurer, Capital Insurance and Surety Company, Inc. He alleged that while employed as a steel man by the defendant corporation, he was accidentally struck by a steel plate and suffered injuries. He sought damages in the amount of P2,800. The defendants filed a motion to dismiss the complaint. The trial judge, Hon. Manuel P. Barcelona, granted the motion and dismissed the case on the ground that the court lacked jurisdiction. The judge based his order on Section 46 of the Workmen’s Compensation Act ( Republic Act No. 772 ), which vested exclusive jurisdiction over such claims in the Workmen’s Compensation Commissioner, and on Section 5 of the same Act, which provided that the rights and remedies under the Act exclude all other rights and remedies against the employer under the Civil Code or other laws for the same injury. The plaintiff appealed the dismissal order.

ISSUE

Whether the Court of First Instance had jurisdiction to entertain the plaintiff’s action for damages against his employer for a work-related injury under the Civil Code, or whether such claim fell under the exclusive jurisdiction of the Workmen’s Compensation Commission as provided by the Workmen’s Compensation Act.

RULING

The Supreme Court affirmed the order of dismissal. The Court held that the trial judge properly applied the law. Section 5 of the Workmen’s Compensation Act explicitly states that the rights and remedies granted by the Act to an employee for a compensable injury exclude (“shall exclude”) all other rights and remedies accruing against the employer under the Civil Code and other laws for that injury. Furthermore, Section 46 of the same Act grants the Workmen’s Compensation Commissioner exclusive jurisdiction to hear and decide claims for compensation under the Act. The Court rejected the appellant’s interpretation that these provisions only applied if a claim had already been filed with the Commission. The Legislature intended, for reasons of expediency and uniformity, that all claims by workmen against employers for damages from employment-related accidents be investigated and adjudicated solely by the Workmen’s Compensation Commission, subject to appeal. This principle of exclusive remedy and jurisdiction was supported by prior decisions of the Supreme Court (Castro vs. Sagales and Abueg vs. San Diego). Therefore, the civil court had no jurisdiction over the complaint. The judgment was affirmed without costs.