Hernando v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Municipal Judge Arsenia Sauco-Hernando was diagnosed with endometriosis, myoma, and uterus cancer during her employment. She underwent surgery and subsequently filed a Notice of Injury or Sickness and Claim for Compensation. An award was rendered granting her disability benefits of P6,000.00, with a reservation on the claim for reimbursement of medical expenses. Procedural History: Claimant Arsenia Sauco-Hernando died before receiving payment. Her husband, Recaredo Hernando, substituted her and was paid the P6,000.00 disability award. Recaredo Hernando then filed a demand for reimbursement of medical expenses amounting to P28,301.57. The Workmen's Compensation Commission (WCC) allowed only P2,913.41 of the claimed medical expenses, ruling that the employer's obligation to provide medical services ceases upon the award of total and permanent disability benefits. The Petition: Recaredo Hernando filed a petition for review, assailing the WCC's decision to limit the reimbursement of medical expenses.
Issue(s)
Whether the Workmen's Compensation Commission erred in holding that the employer's obligation to provide medical, surgical, and hospital services and supplies ceases after the commutation of compensation on the basis of total and permanent disability. Whether the Workmen's Compensation Commission erred in holding that the claimant was no longer entitled to medical, surgical, and hospital services and supplies after being declared totally and permanently disabled. Whether the Workmen's Compensation Commission erred in allowing only P2,913.41 of the P28,301.57 claimed for reimbursement of medical expenses.
Ruling
The Supreme Court modified the decision of the Workmen's Compensation Commission, ordering the respondent to pay the petitioner the full amount of P28,301.57 as reimbursement for medical expenses, provided they are supported by proper receipts.
Ratio Decidendi
On the cessation of employer's obligation for medical expenses upon declaration of total and permanent disability: The Supreme Court held that the Workmen's Compensation Act, as amended, does not distinguish between medical expenses incurred before and after disability has been declared. Unlike provisions for compensation for disability, the law does not provide a maximum amount or time period for availing medical benefits. The implication is that such medical expenses as may be necessary until the work-connected injury or sickness ceases may be charged against the employer. The Court cited Cebu Portland Cement Company vs. Workmen's Compensation Commission to support this interpretation, emphasizing that the law's intent is to provide relief and security to the workman. Therefore, the WCC's ruling that the obligation ceases upon the award of total and permanent disability was erroneous. On the entitlement to medical services after declaration of total and permanent disability: The Court found it erroneous for the WCC to state that a claimant declared totally and permanently disabled is no longer entitled to medical services for recovery. The Court clarified that the purpose of medical services is to promote early restoration to the maximum level of physical capacity. While a totally and permanently disabled person may not fully recover, the medical services are still necessary to manage the condition and alleviate suffering. The WCC's reasoning that a totally and permanently disabled person could no longer recover their physical capacity was a misinterpretation of the law's intent regarding ongoing medical care. On the amount of medical expenses to be reimbursed: The Supreme Court ruled that the petitioner is entitled to reimbursement of medical expenses incurred by the deceased-claimant in the full amount of P28,301.57, provided that these expenses are supported by proper receipts. This ruling directly contradicts the WCC's decision to allow only P2,913.41. The Court's reliance on established jurisprudence, such as Cebu Portland Cement Company and Manansala vs. Republic, underscored the liberal construction of the Workmen's Compensation Act in favor of the employee. The fact that the claim was uncontroverted and affirmed in a previous award further supported the entitlement to full reimbursement.
Main Doctrine
The employer's obligation to provide medical, surgical, and hospital services and supplies under the Workmen's Compensation Act does not cease upon the commutation of compensation on the basis of total and permanent disability; such obligation continues as long as the medical expenses are necessary until the work-connected injury or sickness ceases.