Franklin Baker Co. v. Diamante
REITERATIONFacts
The Antecedents: Respondent Florencio Diamante, a coconut sheller for petitioner Franklin Baker Co. of the Philippines, contracted pulmonary tuberculosis, rendering him disabled for work starting September 7, 1959. He filed a claim for disability compensation. Procedural History: The hearing officer granted compensation. The company appealed to the Workmen's Compensation Commission (WCC), which affirmed the decision, ordering the company to pay P2,461.60 in lump sum and P14.48 weekly until the ailment is arrested or cured, not exceeding 208 weeks, and to provide necessary medical services. The Petition: The company reported completion of 208 weeks of payment. Diamante then petitioned for an extension of compensation beyond 208 weeks, citing continued disability and ongoing medical treatment by the company physician. The company opposed, but the WCC en banc, without a formal hearing, granted the extension, ordering weekly payments until the ailment is arrested or cured, not exceeding the P4,000.00 maximum. The WCC denied the company's motion for reconsideration. Hence, this petition for review.
Issue(s)
Whether the Commission en banc has original jurisdiction to hear and decide a petition for extension of the period of compensation under Section 18 of the Workmen's Compensation Act. Whether the Commission en banc, in issuing its order dated November 6, 1963, without a formal hearing, acted with grave abuse of discretion and without due process of law. Whether an award of compensation that has been satisfied may be reopened for extension of the payment period. Whether compensation benefits for temporary total disability may be extended beyond the general limitation of 208 weeks.
Ruling
The petition for review is dismissed, and the decision and order of the Workmen's Compensation Commission are affirmed.
Ratio Decidendi
On the jurisdiction of the Commission en banc: The Court held that upon the abolition of the "Office of the Workmen's Compensation Commissioner" by Reorganization Plan 20-A, its powers were absorbed by the Workmen's Compensation Commission. The term "Workmen's Compensation Commissioner" in the Act now refers to the Commission itself or its Commissioners. Therefore, the Commission en banc, or any of its Commissioners, can act on a petition for extension of compensation. The fact that the petition was assigned to the original deciding Commissioner and concurred in by the other two Commissioners indicated a collective ruling, and the petitioner's rights were not prejudiced. On grave abuse of discretion and due process: The Court found no grave abuse of discretion or violation of due process. The company's own report dated September 13, 1963, stated that the claimant was still under medical treatment, which clearly indicated continued incapacity for work. This report provided the basis for the Commission's order granting the extension under Section 18 of the Workmen's Compensation Law. The company's submission of this report effectively supplied the justification for the Commission's action. On reopening satisfied awards and extending expired periods: The Court affirmed that an award of compensation, even if satisfied, may be reopened for an extension of the payment period. This is explicitly allowed by Section 18 of the Workmen's Compensation Act, as amended, provided the total compensation does not exceed P4,000.00. The employer's own report of continued medical treatment for the claimant incontrovertibly evidenced further incapacity, justifying the extension. On extending compensation beyond 208 weeks: The Court reiterated that Section 18 of the Workmen's Compensation Act, as amended, authorizes the Commission to extend the period of compensation beyond the 208 weeks specified in Section 14, as long as the total compensation does not exceed P4,000.00. The proviso in Section 18 allows the Commissioner to examine the disabled laborer's condition and extend compensation if necessary. The Court noted that this provision, as amended by Republic Act 772, increased the maximum from P3,000.00 to P4,000.00 and introduced the possibility of extension without a specified time limit, primarily for the benefit of the employee.
Main Doctrine
The Workmen's Compensation Commission has the authority to extend the period of compensation beyond 208 weeks, even after an award has been satisfied, provided the total compensation does not exceed P4,000.00, and the employee is still incapacitated and undergoing medical treatment, as evidenced by the employer's own report.