Hernandez v. Deputy Minister of Labor Inciong
REITERATIONFacts
The Antecedents: Petitioner Generosa S. Hernandez was employed as a classroom teacher from 1946 until 1958, when she became head of the Pilipino Department. In January 1968, she began experiencing chest pains, dizziness, fatigability, and weakness, diagnosed as hypertension and diabetes mellitus. On March 8, 1970, she suffered a stroke, diagnosed as cerebro-vascular accident, cerebral thrombosis secondary to essential hypertension and diabetes mellitus, leading to hospitalization and subsequent physical therapy. She resumed work on July 6, 1970, but soon after applied for retirement at age 61 due to deteriorating health, receiving retirement benefits. Procedural History: On August 9, 1971, petitioner filed a claim for disability compensation and medical benefits. A Hearing Officer granted the claim, awarding P6,000.00 for disability and P940.07 for medical expenses, finding the illness precipitated or aggravated by her duties and that respondents failed to rebut the presumption of compensability and were estopped from contesting due to failure to file a notice of controversion within the prescribed period. Ironically, petitioner died on the same day the Hearing Officer rendered the decision. The Workmen's Compensation Commission reversed the Hearing Officer's decision, dismissing the claim, stating that hypertension is a symptom, not a disabling ailment in the absence of complications, and that the ailments appeared to be due to old age, not causing loss of earning capacity until retirement. Petitioner's motion for reconsideration was denied by the Secretary of Labor, first by Blas I. Ople and subsequently by Amado G. Inciong, on the ground that the decision had become final and executory. The Petition: Petitioner, substituted by her sister Consuelo S. Hernandez, filed a petition for review, questioning the denial of her claim and the finding that the Commission's decision had become final and executory.
Issue(s)
Whether petitioner, having been paid her salary during the period of disability and her retirement benefits, was still entitled to disability compensation and reimbursement of medical expenses incurred. Whether the decision of the Workmen's Compensation Commission dated October 9, 1975, had become final and executory.
Ruling
The petition is granted. The decision of the Workmen's Compensation Commission dated October 9, 1975, is reversed, and the Orders dated February 6, June 9, and September 13, 1978, are set aside. Respondent Republic of the Philippines is ordered to pay petitioner disability compensation and medical expenses.
Ratio Decidendi
On the entitlement to disability compensation and medical expenses: The Court reiterated its ruling in Hernandez vs. Workmen's Compensation Commission (14 SCRA 219) and Afable vs. Workmen's Compensation Commission, et al. (135 SCRA 336) that an employee forced to retire ahead of schedule due to illness contracted in the course of employment is entitled to disability compensation for the loss of earning capacity, in addition to retirement benefits. The Court clarified that no disability compensation is due during periods of hospitalization and recuperation if the employee was paid their salary, as there was no loss of earning capacity during those specific times. However, for the period from July 1970 until her compulsory retirement date on June 16, 1974, during which her disability caused loss of earning capacity, she should be compensated. The Court also affirmed the entitlement to reimbursement of medical expenses, citing Section 13 of the Workmen's Compensation Act, which mandates the employer to provide necessary services, appliances, and supplies for the employee's recovery and rehabilitation. On the finality of the Commission's decision: The Court found the conclusion of the Secretary of Labor that the Commission's decision had become final and executory to be erroneous. The records showed that the decision dated October 9, 1975, was received by petitioner's counsel only on October 16, 1977. Consequently, the motion for reconsideration filed on October 7, 1977, was seasonably filed. Therefore, the decision had not yet become final and executory when the motion for reconsideration was filed, allowing the Court to review the merits of the case.
Main Doctrine
An employee forced to retire ahead of schedule due to illness contracted in the course of employment is entitled to disability compensation for the period of lost earning capacity, in addition to retirement benefits. The employer is also liable for reimbursement of medical expenses incurred. A decision of the Workmen's Compensation Commission is not final and executory if the motion for reconsideration was filed seasonably.