Lerma v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Benjamin Agustin filed a claim for disability compensation and medical expenses against his former employer, Teodoro R. Lerma, doing business as Kwik-Way Engineering Works. Agustin alleged he was employed as a latheman from August 1960 to May 13, 1963, contracting pulmonary tuberculosis aggravated by his work, leading to his separation. He claimed P800.00 in medical expenses. Procedural History: The Hearing Officer found Agustin suffered from compensable pulmonary tuberculosis, disabling him from May 13, 1963, to August 12, 1963 (88 days), ordering the employer to pay P226.28. The claim for continuous medical treatment and P800.00 medical expenses was denied. On appeal, the Workmen's Compensation Commission (WCC) set aside the decision, ordering the employer to pay disability benefits for 208 weeks (P3,744.00), P450.00 in attorney's fees, reimburse P500.00 for medication, and provide continuous medical treatment. The WCC en banc affirmed this ruling. The Petition: The employer sought review, contesting the 208-week disability award and the order for continuous medical treatment and reimbursement, arguing the claimant should have recovered by February 12, 1964, and his separation was voluntary.
Issue(s)
Whether the employer is liable for disability compensation for the maximum period of 208 weeks. Whether the employer is liable for continuous medical, surgical, and hospital services until the claimant's illness is cured or arrested, despite the claimant's resignation. Whether the employer is liable for reimbursement of medical expenses incurred by the claimant.
Ruling
The Supreme Court affirmed the decision and resolution of the Workmen's Compensation Commission. The employer was ordered to pay disability benefits for 208 weeks, reimburse P500.00 for medical expenses, and provide continuous medical treatment until the claimant's illness is cured or arrested.
Ratio Decidendi
On the duration of disability compensation: The Court held that the employer failed to prove that the claimant's illness was cured or that its persistence was due to the claimant's fault. While an x-ray showed residual fibrotic spots, the examining physician did not categorically declare a cure, only that the disease was inactive. The physician's recommendation for clerical work and continued medication for six months indicated ongoing disability. Furthermore, the claimant was denied clerical work and was practically forced to resign due to the risk of contaminating other workers, making recovery conditions difficult to obtain, which was not attributable to the claimant's fault. On the employer's liability for continuous medical treatment: The Court ruled that Section 13 of the Workmen's Compensation Act does not require the continuation of an employer-employee relationship for medical attendance liability to accrue. It is sufficient that the illness was contracted or aggravated during employment. This liability subsists until the ailment is cured or arrested. The Court cited precedents establishing that the employer's obligation for medical attendance is not limited by time or amount, as long as it is necessary for the cure or arrest of the work-connected ailment. The employer failed to prove that the claimant unreasonably refused or impeded medical services. On the reimbursement of medical expenses: The Court sustained the WCC's award for reimbursement of P500.00. Evidence showed the claimant incurred expenses for doctor's fees, drugs, and necessary food for about 10 months. Considering the nature of tuberculosis, these expenditures were deemed reasonable. The WCC correctly deducted the P300.00 advanced by the employer from the total claimed expenses.
Main Doctrine
An employer's liability to provide medical treatment to an employee for an illness contracted or aggravated during employment subsists until the ailment is cured or arrested, irrespective of the continuation of the employer-employee relationship, unless the employee unreasonably refuses or impedes such services.