Sarmiento Engineering Corporation v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Deceased Jose F. Delena, employed as a shop supervisor by petitioner Sarmiento Engineering Corporation from 1968 until his death on December 11, 1974, was diagnosed with a kidney disease and later cancer. He underwent hospitalization and treatment, incurring expenses for medicines, X-rays, and professional fees, which he paid for using his own money, despite receiving his full salary during his sickness. Procedural History: The Workmen's Compensation Commission (WCC) ordered petitioner to pay the claimant, Maxima Vda. de Delena (widow of the deceased), the sum of P2,633.25, representing the unpaid hospitalization and medical expenses advanced by the deceased, less previous advances. The Petition: Petitioner sought a review of the WCC's decision, questioning the order to pay for the extra hospitalization and medical expenses advanced by the deceased, which were not covered by the employer's direct provision.
Issue(s)
Whether the hospitalization and medical expenses advanced by the deceased employee should be paid by the employer and not deducted from death benefits. Whether the WCC correctly ordered the petitioner to pay the claimant for the extra hospitalization and medical expenses advanced by the deceased.
Ruling
The petition for certiorari is dismissed, and the decision of the Workmen's Compensation Commission is affirmed.
Ratio Decidendi
On the issue of employer's liability for advanced expenses: The Court affirmed the WCC's ruling that the petitioner was liable for the hospitalization and medical expenses advanced by the deceased employee. Section 13 of the Workmen's Compensation Act clearly mandates that an employer or insurance carrier shall provide an employee suffering from injury or sickness with necessary services, appliances, and supplies. The law further stipulates that if the employer or insurance carrier cannot furnish these promptly, the injured or sick employee may acquire them at the employer's expense. This provision underscores the employer's obligation to cover such costs to promote the employee's recovery and restoration to their maximum physical capacity. Therefore, these expenses are distinct from and should not be deducted from the death benefits accruing to the deceased's heirs. The employer's obligation is to provide for the necessary medical needs during the period of disability, and any expenses incurred by the employee due to the employer's failure to promptly provide these necessities are reimbursable. The WCC's order to pay the claimant the sum of P2,633.25, representing the unpaid expenses, was therefore in accordance with the law. On the issue of the WCC's order: The Court found no reversible error in the WCC's decision. The WCC correctly applied Section 13 of the Workmen's Compensation Act in ordering the petitioner to reimburse the claimant for the hospitalization and medical expenses advanced by the deceased. The petitioner did not dispute the compensability of the disease, and the facts clearly showed that the deceased incurred these expenses because they were not fully covered by the employer's direct provision. The amount ordered was based on the actual expenses incurred by the deceased, as supported by receipts. Thus, the WCC's order was a proper implementation of the law to ensure that the employee or their heirs are not prejudiced by the employer's failure to provide prompt and complete medical assistance.
Main Doctrine
Under Section 13 of the Workmen's Compensation Act, an employer is liable to provide an employee suffering from sickness with necessary services, appliances, and supplies, and if the employer cannot furnish these promptly, the employee may acquire them at the employer's expense. These expenses should not be deducted from the death benefits due to the heirs.