Andes v. Republic of the Philippines
REITERATIONFacts
The Antecedents: Gregorio Andes, Sr., an employee of the Bureau of Public Schools, sustained an injury while traveling on a PAL plane on official business. He filed a claim for compensation and reimbursement of medical expenses. Procedural History: The Regional Office No. VI, Workmen's Compensation Unit, granted an award in favor of Andes, Sr., ordering the Bureau of Public Schools to pay compensation, reimburse medical expenses, extend further medical services, and pay attorney's fees and administrative fees. The award became final and executory as no appeal was filed. The respondent paid all adjudicated amounts except for Item No. 3 regarding further medical services. The Petition: Andes, Sr. filed a claim for reimbursement of medical expenses incurred from 1972 to December 31, 1975, amounting to P19,818.00. The Secretary of Labor denied this claim, reasoning that a finding of permanent total disability is inconsistent with a grant of further medical services, as no subsequent medication could restore the injured to his maximum physical capacity. The Supreme Court reviewed this denial.
Issue(s)
Whether the Secretary of Labor could modify an award that had become final and executory. Whether the petitioner was entitled to reimbursement for medical expenses incurred after being declared permanently and totally disabled.
Ruling
The Supreme Court set aside the Order of the Secretary of Labor dated April 27, 1977, and ordered the Bureau of Public Schools to pay the petitioner the amount of P19,818.00 representing medical expenses incurred from 1972 to December 31, 1975, supported by proper receipts, after a proper hearing.
Ratio Decidendi
On the issue of modifying a final and executory award: The Court held that the award in favor of the petitioner by the Acting Referee of Regional Office No. VI, Naga City, was admittedly final and executory. Therefore, no part thereof could be modified, even by the Secretary of Labor. The basic rule of finality of judgments is applicable to all, whether public or private employers, as it is grounded on fundamental considerations of public policy and sound practice. The Court cited Carreon vs. Workmen's Compensation and Vitug vs. Republic to reaffirm this principle, emphasizing that judgments must become final at a definite date fixed by law. On the entitlement to reimbursement for medical expenses after permanent total disability: The Court found the contention that the petitioner was no longer entitled to reimbursement because of his declared permanent total disability to be without merit. The Court clarified that the petitioner has a right to seek further improvement of his physical condition and to receive medical treatment to alleviate pain resulting from the injuries sustained. The denial by the Secretary of Labor was based on an incorrect premise that further medical services cease to exist once a disability is declared permanent and total. The Court reiterated that all that needed to be determined was whether the expenses were actually incurred by reason of the injury sustained while on official business, and such expenses were supported by proper receipts.
Main Doctrine
An award that has become final and executory cannot be modified, and an employee is entitled to reimbursement for medical expenses incurred due to a work-related injury, even if declared permanently and totally disabled, as the right to seek further improvement and alleviate pain persists.