Salas v. Republic of the Philippines
REITERATIONFacts
The Antecedents: Claimant Alberto L. Salas began working for the National Economic Development Authority (NEDA) in May 1961 and rose to the position of Professional Management Analyst. He contracted pulmonary tuberculosis in 1969 and suffered intermittent work absences. On February 12, 1974, he filed a claim for compensation (First Case) for pulmonary tuberculosis and chronic bronchial asthma, alleging disability. NEDA controverted the claim, doubting its work-connection. An Acting Referee found the ailment compensable and ordered NEDA to pay compensation benefits, medical expenses, and attorney's fees. NEDA appealed to the Workmen's Compensation Commission (WCC). On July 25, 1974, the Solicitor General recommended payment, and NEDA effected payment. Meanwhile, Salas returned to work on May 16, 1974, and continued until July 9, 1974, when advised to retire, effective July 10, 1974. On January 30, 1975, Salas filed a second claim (Second Case) for chronic bronchial asthma and PTB, stating he stopped work on July 9, 1974. NEDA acknowledged voluntary payments made. An Acting Referee allowed compensation in the Second Case. NEDA sought review, arguing the claim was already adjudicated in the First Case. The WCC modified the decision, allowing disability compensation and reducing medical expenses, directing NEDA to pay a total of P10,664.99. NEDA moved for reconsideration, reiterating its position that compensation had already been awarded in the First Case and that any further award should be limited to the difference between the maximum and the amount already paid. On January 7, 1977, the Secretary of Labor, acting as Head of the Compensation Appeals and Review Staff, modified the WCC decision, reducing the award to P1,529.72 and attorney's fees to P152.97, holding that the maximum compensation of P6,000.00 under the Workmen's Compensation Act could not be violated by treating a recurrence as a distinct disability. Procedural History: The WCC rendered a decision on February 13, 1976, dismissing the First Case, but there was confusion as NEDA had already made payments. The Second Case was filed on January 30, 1975. An Acting Referee allowed compensation. The WCC modified this decision on March 5, 1976. NEDA moved for reconsideration on March 30, 1976. The Secretary of Labor issued an Order on January 7, 1977, modifying the WCC decision. The claimant filed the present Petition for Review. The Petition: The claimant sought review of the Order dated January 7, 1977, of the Secretary of Labor, raising issues regarding the jurisdiction of the Secretary of Labor to decide a case after it had become final and executory, and whether the amount received in a previous case could be deducted from a subsequent award.
Issue(s)
Whether the Secretary of Labor, acting as Head of the Compensation Appeals and Review Staff, could still decide a case of the Workmen's Compensation Commission after the decision had already become final and executory. Whether the Secretary of Labor, assuming jurisdiction, could deduct the amount received by the claimant in a previous case from the award in the second case.
Ruling
The Order of the Secretary of Labor dated January 7, 1977, is set aside. The respondent National Economic Development Authority (NEDA) is ordered to pay Alberto L. Salas P6,000.00 as disability compensation and P4,664.99 as reimbursement for medical expenses; to claimant's counsel P600.00 as attorney's fees; and to the successor of the Workmen's Compensation Commission the corresponding administrative fees.
Ratio Decidendi
On the issue of the Secretary of Labor's jurisdiction: The Court held that procedurally, the decision in the Second Case had already become final and executory due to NEDA's failure to appeal within the reglementary period. Therefore, there was no decision that the Compensation Appeals and Review Staff, headed by the Secretary of Labor, could validly review. The Court emphasized that the appellate body could not act on a matter that had already attained finality. This procedural defect rendered the subsequent review by the Secretary of Labor invalid. On the issue of deducting previous compensation: The Court upheld the petitioner's contention that the Second Case involved a separate and distinct cause of action from that adjudicated in the First Case. The Court cited Earnshaws Docks and Honolulu Iron Works vs. Sortijas to support the principle that for every illness contracted and for every recurrence thereof, a corresponding cause of action accrues. This means that a recurrence or reactivation of an illness gives rise to a cause of action distinct and separate from the original illness. Consequently, each disability, including its recurrence, is entitled to its own maximum compensation under the Workmen's Compensation Act. The employer, by re-employing the claimant with knowledge of the risk of recurrence, accepts the burden of potential liability for a second disability. Therefore, the amount received for the first disability should not be deducted from the award for the second, separate disability.
Main Doctrine
A recurrence or reactivation of an illness gives rise to a cause of action distinct and separate from the cause of action brought about by the illness as originally contracted, entitling the employee to a separate maximum compensation for each disability.