ALHAMBRA CIGAR AND CIGARETTE MANUFACTURING COMPANY, INC., PETITIONER AND APPELLEE, VS. THE REGIONAL ADMINISTRATOR OF REGIONAL OFFICE NO. 2, DEPARTMENT OF LABOR; EUGENIO A. CALED…

Alhambra Cigar and Cigarette Manufacturing versus Caleda

The Case

This is a petition for certiorari and prohibition with preliminary injunction filed by Alhambra Cigar and Cigarette Manufacturing Company against the Regional Administrator and the Hearing Officer of Regional Office Number 2 of the Department of Labor, and against its former driver Francisco Atip. Alhambra sought to stop the regional office from hearing Atip's claim for compensation under the Workmen's Compensation Law, which Alhambra insisted was long barred. The case matters because the Supreme Court uses it to separate two things students often blur: venue in the special civil actions, and jurisdiction over the person or office whose acts are challenged. It also reminds us that an erroneous ruling by a labor hearing officer is an error of judgment, correctable on appeal, not a ground for certiorari.

Procedural History

Francisco Atip filed his claim with Regional Office Number 2 of the Department of Labor at Tuguegarao, Cagayan. Alhambra moved to dismiss on the ground that the claim was barred. Hearing Officer Eugenio Caleda denied the motion, holding that because Atip had been treated at the company's expense, notice of sickness was no longer necessary. Alhambra's motion for reconsideration was denied. Alhambra then filed a petition for certiorari and prohibition with preliminary injunction in the Court of First Instance of Manila. That court issued the preliminary injunction, denied the motions to dismiss, and later rendered judgment granting the petition and permanently enjoining the labor officials and Atip from proceeding further. Atip did not appeal. The Regional Administrator and the Hearing Officer appealed directly to the Supreme Court on a question of law.

Facts

Francisco Atip worked for years as a driver of Alhambra at its branch in Echague, Isabela, at a salary of 120 pesos a month, until he resigned in December 1955. In July, August and September 1957 he worked occasionally as a casual driver, paid per trip. As early as July 1954 he gave verbal notice that he was sick. In July 1955 he consulted the company physician, who found high blood pressure and, on X-ray, cardiac enlargement. He was confined and treated at St. Luke's Hospital at the company's expense for hypertensive heart disease. Alhambra therefore had notice of his illness.

On October 22, 1959, Atip filed with Regional Office Number 2 a notice of injury or sickness and claim for compensation against Alhambra, whose principal office is in Manila, for rheumatism leading to paralysis contracted in 1954. Alhambra moved to dismiss, arguing the claim was long barred under the Workmen's Compensation Act. Hearing Officer Caleda denied the motion.

Alhambra then went to the Court of First Instance of Manila to annul the hearing officer's actuations and restrain further proceedings. That court granted the writs and permanently enjoined the labor officials, prompting this appeal.

Issues

• Whether or not the Court of First Instance of Manila had jurisdiction to issue writs of certiorari and prohibition, with preliminary injunction, against officers of Regional Office Number 2 of the Department of Labor stationed at Tuguegarao, Cagayan.
• Whether or not the Hearing Officer acted in excess of jurisdiction or with grave abuse of discretion in denying the motion to dismiss and proceeding with the claim.

Applicable Provisions

Section 4, Rule 67 of the old Rules of Court, now Section 4 of Rule 65, provides:

Sec. 4. Where petition field.—The petition may be filed in the Supreme Court, or, if it relates to the acts or omissions of an inferior court, or of a corporation, board, officer or person, in a Court of First Instance having jurisdiction thereof. It may also be filed in the Court of Appeals if it is in aid of its appellate jurisdiction.

This fixes venue for certiorari, prohibition and mandamus, and ties it to the court having jurisdiction over the officer whose acts are questioned.

Section 44(h) of the Judiciary Act of 1948 provides:

Sec. 44. Original jurisdiction.—Courts of First Instance shall have original jurisdiction: x x x x x x x x x (h) Said courts and their judges, or any of them, shall have power to issue writs of injunction, mandamus, certiorari, prohibition, quo warranto and habeas corpus in their respective provinces and districts, in the manner provided in the Rules of Court.

This limits a court's injunctive power to acts committed or about to be committed within its own province or district.

Section 25, Article VI of Reorganization Plan Number 20-A of the Department of Labor provides:

Each Regional Office shall have original and exclusive jurisdiction over all cases falling under the Workmen's Compensation law, * * *

This confirms that the regional office, not the Manila court, was the proper forum in the first instance.

Ruling

On the first issue, the Court held that the Court of First Instance of Manila had no jurisdiction, and that its actuations were null and void and could not be given effect outside its territorial jurisdiction. Section 4 of Rule 67 concerns venue, and the jurisdiction it alludes to is jurisdiction over the officer whose acts are in question, not over the subject matter. Since the challenged acts were those of officers holding office and acting at Tuguegarao, Cagayan, in the First Judicial District, the petition should have been filed in the Court of First Instance of Cagayan. The Court also stressed that the rule-making power cannot be used to vest the Manila court with authority that the Judiciary Act withholds, and that injunctive power is confined to acts within the court's own province or district.

On the second issue, the Court held that the Hearing Officer acted within his jurisdiction. The regional office has original and exclusive jurisdiction over Workmen's Compensation cases, and whether the claim had prescribed was a matter for that office to determine, subject to appeal to the Workmen's Compensation Commission and ultimately to the Supreme Court. The Court defined the terms:

The term "excess of jurisdiction" signifies that the Court, board or officer has jurisdiction over a case but oversteps such jurisdiction while exercising the same. By "grave abuse of discretion" is meant such capricious and whimsical exercise of judgment, equivalent to lack of jurisdiction.

Not every error of law or fact amounts to excess of jurisdiction. Any error by the Hearing Officer was an error of judgment correctable on appeal, and Alhambra pursued the wrong remedy.

Doctrine

A petition for certiorari and prohibition must be filed in the Court of First Instance having jurisdiction over the officer or person whose acts are questioned, and a court's writ of injunction reaches only acts done within its own province or district. A regional office of the Department of Labor has original and exclusive jurisdiction over Workmen's Compensation cases, and its resolution of a defense such as prescription is an exercise of jurisdiction reviewable by appeal, not by certiorari. Excess of jurisdiction means overstepping jurisdiction already possessed; grave abuse of discretion means capricious and whimsical judgment equivalent to lack of jurisdiction.

Disposition

The Supreme Court reversed the decision below, declared the writs of certiorari, prohibition and injunction null and void, and upheld the authority of the respondents to proceed with the hearing and decision of Atip's claim, with costs against Alhambra.

Remember This

Memorize this line: venue in certiorari and prohibition follows the place where the challenged officer acts, and injunction cannot reach beyond the court's own province. Examiners use this case to test the distinction between jurisdiction and venue in special civil actions, and between an error of judgment and grave abuse of discretion.