ELIODORA C. VDA. DE CORPUZ, PETITIONER, VS. THE COMMANDING GENERAL, PHILIPPINE ARMY, RESPONDENT.

Corpuz versus Commanding General, Philippine Army

The Case

This is a petition for mandamus brought by Eliodora C. Vda. de Corpuz against the Commanding General of the Philippine Army. The petitioner asks the Supreme Court to compel the respondent to pay in full the death compensation benefits awarded to her and her children for the service-connected death of her husband, T/Sgt. Cornelio Corpuz. The respondent had released only part of the award, deducting the sums the widow had earlier received as death gratuity under Republic Act No. 610 and as burial expenses under Section 699 of the Revised Administrative Code. The case matters because it draws the line between the power to decide an award and the duty to obey it: once a judgment is final and executory, the officer charged with its implementation performs a purely ministerial act and cannot, on his own theory of the law, reduce what the judgment commands.

Procedural History

The case began in the Workmen's Compensation Unit of Labor Regional Office No. 4 in Manila, where the Acting Referee rendered a decision awarding the widow and her children death compensation plus burial expenses. That award became final and executory because the Government did not appeal it. The Solicitor General indorsed the award to the respondent Commanding General for payment, but the respondent's office prepared a voucher for a reduced amount, deducting the gratuity and the burial benefit already received. The petitioner protested, and the Office of the President, through Acting Assistant Executive Secretary Ronaldo B. Zamora, ruled in her favor, holding the deduction without legal justification and authorizing payment of the entire award. The respondent refused to comply, insisting that the deduction was in order and that the Army had a cause of action for reimbursement. The Office of the President reiterated its ruling in a second decision, agreeing that the Army might pursue reimbursement through the proper legal remedy but not by deducting from the compensation award. When the respondent still refused to release the balance, the petitioner filed this petition for mandamus directly with the Supreme Court.

Facts

T/Sgt. Cornelio Corpuz died a service-connected death. For that death, his widow, the petitioner, and her children were awarded death compensation of 6,000 pesos plus 200 pesos for burial expenses under the Workmen's Compensation Act. The award became final and executory, and the Solicitor General indorsed it to the Commanding General of the Philippine Army for payment.

Instead of paying the full award, the respondent's office prepared a voucher for only 2,950 pesos. It deducted 3,000 pesos representing the gratuity the petitioner had received under Republic Act No. 610, the Armed Forces Death Gratuity and Disability Pension Act of 1951, and 250 pesos for burial expenses under Section 699 of the Revised Administrative Code. The apparent theory was that benefits under Republic Act No. 610, under Section 699, and under the Workmen's Compensation Act are mutually exclusive.

The petitioner protested vehemently, but the respondent refused full payment. She sought the aid of the Office of the President, which twice ruled in her favor and twice directed payment of the entire award. The respondent, through his Army Adjutant, persisted in refusing, maintaining that the deduction was proper and that the Army could recover the 3,250 pesos already paid. Hence the petition for mandamus.

Issues

• Whether or not mandamus lies to compel the Commanding General of the Philippine Army to pay the full amount of a final and executory award under the Workmen's Compensation Act.
• Whether or not the officer charged with implementing a final and executory award may deduct from it the gratuity and burial benefits the claimant received under other laws.
• Whether or not the doctrine allowing such deduction, laid down in the Doyon case, applies where the compensation award has already become final and executory.

Applicable Provisions

Section 5 of the Workmen's Compensation Act, as amended, provides:

Sec. 5. Exclusive right to compensation. - The rights and remedies granted by this Act to an employee by reason of a personal injury entitling him to compensation shall exclude all other rights and remedies accruing to the employee, his personal representatives, dependents or nearest of kins against the employer under the Civil Code and other laws, because of said injury.

This is the provision the respondent invokes to argue that compensation under the Act excludes the other benefits, and therefore that the deduction was proper.

Section 9 of Republic Act No. 610, as amended, provides:

Sec. 9. Repeal or modification of laws. - Except as hereinafter provided, any gratuity or pension received under the provisions of this Act shall be in addition to any retirement pay payable under existing laws. Provided, That no person who has received the death or disability benefits under Republic Act Numbered Five hundred seventy-three shall be entitled to the benefits of this Act. No payment shall hereafter be made to the beneficiaries of deceased officers and enlisted men of the Armed Forces of the Philippines or the Philippine Constabulary under the provisions of Republic Act Numbered Thirty or any other law granting similar benefits to officers and employees, generally, of the national, provincial, or municipal government.

This is the provision the respondent reads as barring payment under other laws, which the Court holds cannot be applied to reopen an award already final.

Ruling

On the first issue, the Court holds that mandamus is the proper remedy. The respondent's insistence on deducting from a final and executory award is an unlawful act of excluding the petitioner from the use and enjoyment of a right to which she is entitled under the law. A final and executory award entitles her to enforcement according to its letter, and it is not susceptible of any change or alteration by the officer charged with its implementation, because that officer's duty is a ministerial act that does not call for the exercise of discretion. His adamant refusal is also an unlawful neglect to perform an act which the law specifically enjoins as a duty resulting from his office. There being no other plain, speedy and adequate remedy, the writ lies.

On the second issue, the Court rejects the respondent's theory. To insist on reducing a final award is, in effect, to review it, and no such review is authorized. The Court adopts the reasoning of the Falcon versus Mathay case, squarely in point, where the Auditor General was compelled to approve for payment a final award of the Workmen's Compensation Commission against the Republic, because the denial of the claimed deduction had itself become final and the officer had no alternative but to approve payment.

On the third issue, the Court holds that the Doyon doctrine does not apply. In Doyon, the payment of gratuity under Republic Act No. 610 and the burial benefit under Section 699 were properly and timely raised before the hearing officer, so the deduction could be considered in the award itself. Here, those facts were never brought to the hearing officer's attention, and the award became final because the Solicitor General did not appeal. The finality of the award, undisputed, closes the case against the respondent. The Court declines the petitioner's invitation to re-examine the Doyon doctrine, because in a suit for mandamus any opinion on that doctrine would not be necessary to the decision and would merely be an obiter dictum, and because it would collaterally put in issue the validity of a final judgment, which may not be done absent lack of jurisdiction, irregularity apparent on the face of the record, or fraud.

Doctrine

A judgment that has become final and executory is immutable and enforceable according to its letter; the public officer charged with its implementation performs a ministerial duty and may not alter, reduce, or review the award by deducting amounts paid under other laws. Mandamus lies to compel that ministerial act where the officer unlawfully neglects to perform a duty specifically enjoined by law, and no other plain, speedy and adequate remedy exists. The doctrine permitting deduction of gratuity and burial benefits from a workmen's compensation award applies only where those facts were timely raised before the hearing officer and passed upon in the award itself; it cannot be invoked to reopen an award already final. The validity of a final judgment may not be attacked collaterally in a mandamus suit except for lack of jurisdiction, irregularity apparent on the face of the record, or fraud.

Disposition

The writ of mandamus was granted, ordering the Commanding General of the Philippine Army to pay the petitioner the 3,250 pesos unlawfully deducted from her award of 6,200 pesos under the Workmen's Compensation Act, with no costs.

Remember This

Memorize this line: a final and executory award cannot be reduced by the officer who implements it, for his duty is ministerial and mandamus will compel full payment. Examiners use this case to test the finality of judgments, the ministerial nature of the duty to execute, and the limits of the Doyon doctrine on deducting gratuity from workmen's compensation.