Bello v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Lourdes S. Bello, a public school teacher employed in 1965, filed a claim for illness compensation under Act 3428 against the Republic of the Philippines (Bureau of Public Schools). She alleged that in the performance of her duties, she was exposed to weather elements. On September 11, 1973, she became sick with Pulmonary Tuberculosis, Minimal with fibrosis, which her physician, Dr. Rodolfo P. Alano, stated was a result of her employment. Claimant stopped working on October 1, 1973, due to her illness, and her services were terminated by the respondent. She had received her salaries up to the time of her separation. Procedural History: The Workmen's Compensation Unit, Regional Office No. 10, Zamboanga City, found that the illness supervened during employment and was presumed to have arisen out of it. The respondent did not file a controversion. Claimant was evaluated by Dr. Romulo P. Montecillo to be suffering from permanent partial disability to the extent of 12% N.S.D. The Unit awarded disability compensation benefits of P823.16, attorney's fees of P41.00, and administrative fees of P9.00. Petitioner filed a motion for reconsideration, claiming the decision did not address her main claim for illness compensation under Sections 14 or 16 and medical care under Section 13. The motion was denied, and the case was elevated to the Workmen's Compensation Commission (WCC). The WCC affirmed the award. The Petition: Petitioner sought modification of the WCC decision, arguing that since she was forced to resign due to her sickness (pulmonary tuberculosis) to safeguard pupils, and became jobless and unable to receive salary, she was entitled to disability compensation under Section 14 of the Act for a period of four years (maximum), equivalent to 60% of her average weekly wage, from the time of resignation until compulsory retirement at age 65. She cited the case of Ciriaco Hernandez vs. MERALCO and WCC.
Issue(s)
Whether the claimant is entitled to disability compensation for total disability under Section 14 of the Workmen's Compensation Act. Whether the claimant is entitled to medical services and supplies under Section 13 of the Workmen's Compensation Act. Whether the award of P823.16 was sufficient compensation given the claimant's condition and potential loss of earning capacity.
Ruling
The Supreme Court modified the decision of the respondent Commission. It ordered the Bureau of Public Schools and/or Republic of the Philippines to pay Lourdes S. Bello P6,000.00 as compensation benefits, expenses for medical and hospital bills duly supported by receipts, and attorney's fees of P600.00. It also ordered the provision of continuous medical and hospital services and supplies if the illness still subsists, and payment of P61.00 as administrative fees to the Workmen's Compensation Commission.
Ratio Decidendi
On the entitlement to disability compensation for total disability under Section 14 of the Workmen's Compensation Act: The Court found the petitioner's claim meritorious. It reiterated that disability occurs when an employee is unable to render further service due to physical inability to perform work in the usual and customary way, signifying a loss or diminution of earning power due to an employment-related injury. The Court emphasized that it is the incapacity to work and the resulting impairment of earning capacity, not the injury itself, that is compensated. In Lourdes Bello's case, her pulmonary tuberculosis compelled her to resign, rendering her unable to work and earn a livelihood. The Court considered this a total disability, not only because she was physically unable to perform her teaching job but also because no employer would likely hire her given her illness. Therefore, she was entitled to compensation under Section 14, which provides for a maximum of P6,000.00. On the entitlement to medical services and supplies under Section 13 of the Workmen's Compensation Act: The Court held that in addition to disability compensation, the petitioner was entitled to be provided with such services and supplies as the nature of her disability and the process of recovery may require, as stipulated under Section 13 of the same Act. This ensures that the employee receives necessary medical attention to facilitate recovery or manage the condition arising from the work-related illness. On the sufficiency of the award: The Court found the initial award of P823.16 insufficient. It reasoned that the claimant's situation was similar to that in Castro vs. Workmen's Compensation Commission, et al., where a compensation of P6,000.00 was awarded to a teacher who left his job due to minimal pulmonary tuberculosis. The Court concluded that Lourdes Bello's disability, which prevented her from continuing her employment and earning a living, warranted the maximum compensation allowed under Section 14 of the Workmen's Compensation Act, which is P6,000.00. The Court also awarded attorney's fees and ordered the provision of ongoing medical care, reflecting a more comprehensive approach to compensating work-related disabilities.
Main Doctrine
An employee suffering from an illness contracted during employment, which leads to inability to work and loss of earning capacity, is entitled to disability compensation under the Workmen's Compensation Act, including medical services and attorney's fees.