CASE DIGEST : Maximo Nocnoc v. Hon. Isidoro A. Vera and Ernesto Manarang G.R. No. L-37737, February 27, 1979

 

FACTS

Maximo Nocnoc filed a claim for death compensation benefits under the Workmen's Compensation Act (Act No. 3428, as amended) after his son, Norberto Nocnoc, died in a work-related accident while employed as a bus conductor by Ernesto Manarang. The claim was filed before the Workmen's Compensation Unit (WCU), Regional District No. 6. Manarang failed to file a timely notice of controversion within the period prescribed by the Workmen's Compensation Act and the Commission Rules. Instead, after the period had lapsed, he moved to dismiss the claim, alleging that he had already amicably settled the claim by paying the claimant ₱2,330.00.

The WCU denied the motion to dismiss and rendered an award in favor of Nocnoc. It held that the amount previously paid constituted only a partial payment and ordered Manarang to pay the remaining ₱3,910.00 as compensation, together with the required administrative fee under Section 55 of the Workmen's Compensation Act. Manarang's motion for reconsideration was denied, and after the decision became final, the WCU issued a writ of execution to enforce the award.

Instead of complying with the award, Manarang filed a complaint for injunction before the Court of First Instance (CFI) of Camarines Norte, presided over by Judge Isidoro Vera. He argued that he had been denied due process because the WCU awarded compensation without conducting a formal hearing. The CFI assumed jurisdiction, issued an injunction restraining the enforcement of the WCU's writ of execution, and denied Nocnoc's motion to dismiss. Nocnoc then filed a petition for certiorari and prohibition before the Supreme Court, contending that the CFI had no jurisdiction to interfere with decisions and execution orders of the WCU.

ISSUE

Whether the Court of First Instance, as a court of general jurisdiction, had the authority to entertain an action questioning the validity of a final award of the Workmen's Compensation Unit and to issue an injunction restraining the execution of its decision.

Whether Manarang could validly invoke denial of due process to challenge the WCU's award despite his failure to timely controvert the compensation claim as required by the Workmen's Compensation Act and the Commission Rules.

Whether the WCU validly rendered an award without conducting a formal hearing after the employer failed to seasonably file a notice of controversion under Sections 37 and 45 of Act No. 3428, as amended, and the implementing Commission Rules.

HELD

The Supreme Court granted the petition and held that the Court of First Instance had absolutely no jurisdiction to entertain the injunction case or restrain the execution of the WCU's final award. The Court explained that Section 46 of the Workmen's Compensation Act vested exclusive authority over compensation cases in the Workmen's Compensation Commission and provided that judicial review of its decisions belonged only to the Supreme Court. The fact that the CFI is a court of general jurisdiction does not authorize it to interfere with matters that the law has placed within the exclusive jurisdiction of a specialized administrative body. Jurisdiction must be conferred by statute and cannot arise merely from the broad description of a court's general powers.

The Court further ruled that Manarang's claim of denial of due process was without merit. Under Sections 37 and 45 of the Workmen's Compensation Act and the Commission Rules, an employer must file a notice of controversion within the prescribed period—within fourteen (14) days from disability or within ten (10) days from acquiring knowledge thereof. Failure to do so constitutes a waiver of defenses and authorizes the WCU to issue an award based solely on substantial evidence without the necessity of a formal hearing. Since Manarang failed to seasonably controvert the claim and had even made a partial payment in an attempt to settle it, he could no longer invoke lack of hearing or denial of due process.

Accordingly, the Supreme Court declared the orders of the CFI null and void for having been issued without jurisdiction, made permanent the temporary restraining order previously issued, and directed that the WCU's award be enforced. The decision reaffirmed the doctrine that specialized administrative agencies exercising exclusive jurisdiction cannot be interfered with by courts lacking statutory authority, and that failure to comply with mandatory procedural requirements under the Workmen's Compensation Act bars an employer from later challenging the award on procedural grounds.