Tabas v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Manuel D. Tabas, a captain in the Philippine Constabulary, suffered a stroke (infarction of the myocardium due to coronary thrombosis) on July 17, 1968, while in the performance of his official duties. He was discharged from service for complete disability on November 20, 1970. He filed a claim for compensation under the Workmen's Compensation Act. Procedural History: The Hearing Officer and Acting Referee rendered a decision on May 5, 1972, ordering the respondent Republic of the Philippines (Philippine Constabulary, AFP) to pay P6,000.00 as disability compensation, P300.00 as attorney's fees, and to provide medical services and reimbursement for expenses incurred for the treatment of his heart disease. The respondent did not appeal this decision and paid P6,000.00 and P710.06 as reimbursement. Petitioner incurred additional medical expenses of P2,835.80. A motion for reimbursement was filed, and the Compensation Rating Medical Officer recommended P2,525.18 as reasonable. An order dated December 25, 1974, directed the respondent to pay this amount. The respondent appealed to the Workmen's Compensation Commission, which set aside the award, opining that no amount of medical attention could restore the claimant to his maximum physical capacity, thus absolving the respondent from further liability. The Petition: Petitioner seeks review of the Workmen's Compensation Commission's decision reversing the award for additional medical expense reimbursement.
Issue(s)
Whether the respondent Republic of the Philippines (Philippine Constabulary, AFP) is liable for the reimbursement of additional medical expenses incurred by the petitioner based on the final and executory decision of the Hearing Officer, Acting Referee, dated May 5, 1972. Whether the final and executory decision of the Hearing Officer, Acting Referee, dated May 5, 1972, is enforceable, and whether the Workmen's Compensation Commission erred in setting aside the award.
Ruling
The Supreme Court ruled in favor of the petitioner, setting aside the decision of the Workmen's Compensation Commission and ordering the respondent to reimburse the petitioner the amount of P2,525.18 for medical and professional expenses.
Ratio Decidendi
On the issue of reimbursement of additional medical expenses and the enforceability of the May 5, 1972 decision: The Court held that the petitioner is entitled to the reimbursement of additional medical expenses. The decision of the Hearing Officer, Acting Referee, dated May 5, 1972, expressly ordered the Philippine Constabulary, AFP, "to provide the claimant such medical, hospital, surgical supplies, appliances and services as the nature of his heart disease may require, and to reimbursement of such medical expenses that may be incurred by him for the treatment of such illness." This decision had become final and executory because the respondent did not appeal it. Therefore, the respondent is bound by its terms and must pay the additional expenses incurred by the petitioner. On the enforceability of the final and executory decision and the error of the Workmen's Compensation Commission: The Court emphasized that a judgment that has become final and executory is immutable and can no longer be modified or set aside. The respondent's failure to appeal the May 5, 1972 decision meant that its order to provide and reimburse medical expenses became the law of the case between the parties. The Workmen's Compensation Commission erred in setting aside the award based on the medical opinion that no amount of attention could restore the claimant to maximum capacity. The original decision did not impose such a limitation on the reimbursement of medical expenses. The Court cited its ruling in Biscarra vs. RP (L-43425) which affirmed the right to such refund. The medical and professional expenses were duly supported by receipts and evaluated by the Compensation Rating Medical Officer, who found the amount of P2,525.18 to be reasonable and fair for the treatment of the petitioner's heart illness.
Main Doctrine
A final and executory decision ordering reimbursement of medical expenses incurred for the treatment of a work-related illness remains enforceable, even if the employee is declared totally and permanently disabled and has received disability compensation, as the employer cannot be absolved from liability for such expenses based on the employee's inability to return to maximum physical capacity.