Tuesday, June 26, 2012

Castro vs Sagales Case Digest

G.R. No. L-6359        




Facts: Republic Act No. 772 effective June 20, 1952 conferred upon the Workmen's Compensation Commissioner "exclusive jurisdiction" to hear and decide claims for compensation under the Workmen's Compensation Act, subject to appeal to this Supreme Court. Before the passage of said Act demands for compensation had to be submitted to the regular courts. The fatal accident which befell Dioscoro Cruz, husband of plaintiff Carmen Cruz, having occurred in January 1952 and action having been commenced in the Court of First Instance of Bulacan in August, 1952 .For the appellants, it is contended that the date of the accident, and not the date of filing the complaint, should be considered because the right to compensation of the laborer or employees or his dependents, like the obligation of the employer to pay the same, begins from the very moment of the accident.


Issue: the resultant issue is the proper forum: either the courts or the Workmen's Compensation Commission


Held: It is true that the right arises from the moment of the accident, but such right must be declared or confirmed by the government agency empowered by law to make the declaration. Republic Act No. 772 is very clear that on and after June 20, 1952 all claims for compensation shall be decided exclusively by the Workmen's Compensation Commissioner, subject to appeal to the Supreme Court. This claim having been formulated for the first time in August,1952 in the Court of First Instance of Bulacan, the latter had no jurisdiction, at that time, to act upon it. No constitutional objection may be interposed to the application of the law conferring jurisdiction upon the Commission, because the statute does not thereby operate retroactively; it is made to operate upon claims formulated after the law's approval. 

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