Jacoba v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Amparo S. Jocoba, a public school teacher, contracted an illness allegedly due to her work. While she was hospitalized during vacation time and continued teaching without interruption during the regular school year, her illness was officially recognized as work-connected by the Division Committee on Workmen's Compensation cases of the Bureau of Public Schools. Procedural History: The petitioner filed a claim for reimbursement of medical expenses with the Regional Office No. 10 at Zamboanga City, which initially awarded her P1,999.66. The respondent, the Republic of the Philippines (Bureau of Public Schools), appealed this decision to the Workmen's Compensation Commission. The Commission, after a motion for reconsideration by the respondent was filed and sent to the petitioner, reduced the award to P596.30. The Petition: This case comes before the Supreme Court as a petition for review of the Workmen's Compensation Commission's order reducing the award for reimbursement of medical expenses. The petitioner argues that the decision of the Hearing Unit of Regional Office No. 10, which awarded the full P1,999.66 based on proper receipts and the evaluation of the Compensation Rating Officer, should be upheld, asserting that the Commission's reduction lacked explanation despite acknowledging the illness as compensable and the incurred medical expenses as reimbursable.
Issue(s)
Whether the decision of the Hearing Unit of Regional Office No. 10 had become final and executory. Whether the Workmen's Compensation Commission erred in reducing the award for reimbursement of medical expenses.
Ruling
The order of the Workmen's Compensation Commission dated March 3, 1976, is set aside. The respondent, Republic of the Philippines (Bureau of Public Schools), is ordered to pay the petitioner the sum of One Thousand Nine Hundred Ninety-Nine Pesos and Sixty-Six Centavos (P1,999.66).
Ratio Decidendi
On the issue of the finality of the decision: The contention that the decision of the Hearing Unit had become final has no merit. The records show that the respondent, Republic of the Philippines (Bureau of Public Schools), seasonably filed a motion for reconsideration. A copy of this motion was sent to the petitioner by registered mail on January 21, 1976, indicating that the decision was not yet final and executory. On the issue of the reduction of the award for medical expenses: The Workmen's Compensation Commission erred in reducing the award. It is undisputed that the illness of the petitioner is compensable and she is entitled to the reimbursement of her medical expenses. The WCC itself acknowledged that the claimant was afflicted with a work-connected illness and incurred medical expenses. The Commission's finding that there was no interruption in her teaching job and thus no disability benefit was awarded does not preclude reimbursement of medical expenses. The Supreme Court, in cases such as Alatco vs. WCC, has held that reimbursement of medical expenses is allowable even if no disability compensation benefit is granted. The award of P1,999.66 was based on the evaluation of Dr. Romulo P. Montecillo, the Compensation Rating Officer, and supported by proper receipts presented by the petitioner, making it reasonable and justifiable.
Main Doctrine
Reimbursement of medical expenses incurred due to a work-connected illness is allowable under the Workmen's Compensation Act, even if no disability compensation benefit is granted.