Centeno v. Workmen's Compensation Commission
REITERATIONFacts
1. The Antecedents: Wenceslao Centeno, an employee of Batangas Laguna Tayabas Bus Company, contracted Pulmonary Tuberculosis, which was deemed a compensable illness. The Workmen's Compensation Commission initially affirmed a referee's decision ordering the bus company to pay Centeno P6,000.00 for disability compensation and to provide necessary medical services and supplies. 2. Procedural History: After receiving the P6,000.00 disability compensation and signing a "Full Satisfaction of Decision," Centeno, who was still undergoing treatment and hospitalization, filed a motion for reimbursement of medical and hospitalization expenses amounting to P1,959.15. The Acting Referee granted this motion, ordering reimbursement and continued provision of medical services. However, the Workmen's Compensation Commission en banc reversed the referee's decision, citing the finality of the original award and the executed satisfaction of decision. 3. The Petition: This petition for review, treated as a special civil action, seeks to overturn the Workmen's Compensation Commission's order denying Centeno's motion for reimbursement of medical and hospitalization expenses. The petitioner argues that the "Full Satisfaction of Decision" only covered the disability compensation and did not waive his right to reimbursement for medical expenses, which is a separate and continuing obligation of the employer under the Workmen's Compensation Act and the New Labor Code.
Issue(s)
Whether the Commission erred in denying the motion for reimbursement of medical and hospitalization expenses filed after the decision became final. Whether the document labeled "Full Satisfaction of Decision" executed by the claimant operates to waive the claimant's right to reimbursement of medical and hospitalization expenses decreed in the September 17, 1975 decision. Whether the regional referee lost jurisdiction to grant execution or relief after the Commission's decision became final and executory. Whether employer liability for medical and hospitalization services continues during the period of disability even after termination of employment.
Ruling
The Supreme Court set aside the order en banc of the Workmen's Compensation Commission dated February 24, 1976 as nullity and reinstated and affirmed the referee's decision of January 20, 1976 directing the respondent to reimburse the claimant P2,047.53 for medical and hospital expenses and to provide necessary services, appliances and supplies.
Ratio Decidendi
On Whether the Commission erred in denying the motion for reimbursement: The Court held that the Commission erred. The referee had properly found that the claimant was still under treatment and incurred medical and hospitalization expenses, and the Act contemplates reimbursement of such expenses under Section 13 during the period of disability. The Court emphasized that a decision, once final and executory, may be the subject of a motion for execution and that the claimant properly filed such a motion under Section 51, Act No. 3428, as amended. The Court further reasoned that statutory protections preclude schemes that would exempt employers from liabilities created by the Act and that the Commission's en banc action improperly allowed such a subterfuge. Consequently, the referee's grant of reimbursement was reinstated because it conformed with the statutory scheme protecting employees' medical benefits. On Whether the "Full Satisfaction" document waived the right to medical reimbursement: The Court found that the document labeled "Full Satisfaction of Decision" was a receipt limited to the P6,000.00 disability compensation and could not be construed as renunciation of the claimant's right to reimbursement of medical and hospitalization expenses decreed in the decision of September 17, 1975. The Court relied on Section 7 of Act No. 3428, which declares null and void "any contract, regulation or device of any sort intended to exempt the employer from all or part of the liability created by this Act," and on Article 174 of the New Labor Code reiterating that no contract shall deprive the employee of income benefits or medical services. The reasoning stressed the protective purpose of labor legislation and that a necessitous employee cannot be presumed to have waived statutory benefits by executing a receipt for a specific sum. The Court therefore concluded the receipt did not extinguish the employer's continuing duty to reimburse medical expenses. On Whether the regional referee lost jurisdiction after the decision became final: The Court clarified procedural mechanics: while the Commission's decision became final and executory, the claimant's filing of a motion for execution was the proper avenue to obtain enforcement of the decree, and the regional office acting under delegated authority retained competence to act on such motion. The Court stated that execution may be sought after finality (citing Sec. 51, Act No. 3428, as amended) and that the referee's action in granting reimbursement was an exercise of execution and enforcement of the final decision. The Commission's reversal on the ground of loss of jurisdiction was therefore improper because the motion for execution was the correct procedural step and the referee had authority to direct reimbursement in execution of the decision. On Whether employer liability for medical services continues during disability even after employment termination: The Court applied settled doctrine that the employer's liability for medical and hospitalization services endures during the period of disability if the illness is compensable and does not require the continued existence of an employer-employee relationship. The Court cited Itogon Suyoc Mines, Inc. v. Dulay to support the proposition that the duty persists as long as the illness was contracted during employment. The ruling emphasized that liability is determined by the compensable nature of the disease and the period of disability, not by the formal status of employment, and therefore the employer remained liable for the claimant's medical expenses incurred during the period of disability.
Main Doctrine
An employer's obligation to provide medical and hospitalization services for a compensable disease continues during the period of disability and cannot be nullified by a document of "full satisfaction" limited to payment of statutory disability compensation.