Franklin Baker Company v. Diamante
REITERATIONFacts
The Antecedents: Respondent-claimant Florencio Diamante, employed by petitioner Franklin Baker Company, contracted pulmonary tuberculosis. He filed a compensation claim (R05-WC Case No. 140) which was decided favorably, awarding benefits. Petitioner satisfied the decision by paying weekly compensation for 208 weeks, terminating on September 4, 1963. Procedural History: After the satisfaction of the original claim, Diamante filed a Petition for Extension of Period of Compensation on October 8, 1963, alleging he was still under treatment. Pending this, he filed a Motion for Reimbursement on November 8, 1963. This motion was initially dismissed but later granted by the Workmen's Compensation Commission (WCC) en banc on July 16, 1968, awarding P1,275.00 for medical expenses. The Petition: Petitioner Franklin Baker Company filed a Petition for Review, assailing the WCC's order granting the motion for reimbursement, arguing the case was already decided, terminated, and satisfied, and that the reimbursement was granted without a hearing.
Issue(s)
Whether the Workmen's Compensation Commission erred in granting the respondent claimant's motion for reimbursement after the case had long been decided, terminated, and the judgment thereon satisfied. Whether the Workmen's Compensation Commission erred in summarily granting the respondent-claimant's motion for reimbursement without the benefit of a hearing.
Ruling
The petition is DISMISSED and the order sought to be reviewed is hereby AFFIRMED.
Ratio Decidendi
On the issue of granting reimbursement after the case was decided and satisfied: The Court held that the WCC did not err. The claim for reimbursement of medical expenses was not a new claim but a corollary to the original decision which had declared Diamante's illness as work-connected and compensable. The original decision had explicitly required the petitioner company to provide necessary medical services until the ailment was arrested or cured. Therefore, granting reimbursement for these services was merely implementing the original decision, not reopening a closed case. The Court emphasized that this was a claim for reimbursement of expenses already incurred for medical services that were part of the compensable award, not a new claim for compensation itself. On the issue of granting reimbursement without a hearing: The Court found no grave abuse of discretion or violation of due process. The WCC had previously issued an order on November 6, 1963, extending the period of compensation beyond 208 weeks, which was affirmed by the Supreme Court in G.R. No. L-22206. This extension was granted under Section 18 of the Workmen's Compensation Act, which allows the WCC to reopen a case for examination and extension of compensation period, provided the total does not exceed P4,000.00. The Court noted that the employer itself had provided further medical assistance, which evidenced continued incapacity. Furthermore, the petitioner was furnished a copy of the motion for reimbursement and the subsequent motion for reconsideration, and it filed an opposition, indicating it had an opportunity to be heard and present its arguments against the reimbursement. The Court cited a similar case where reimbursement was granted without a formal hearing when the employer failed to provide the required medical services promptly.
Main Doctrine
A claim for reimbursement of medical expenses, being corollary to a compensable illness, can be granted even after the main compensation award has been satisfied, provided it implements a prior decision ordering the employer to furnish necessary medical services and the claim is filed within the bounds of the Workmen's Compensation Act, particularly Section 18 concerning the extension of compensation periods.