Batangas Laguna Tayabas Bus Co. v. Perez
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a claim for compensation and medical expenses by Tomas Perez against the Batangas Transportation Company, which later merged with Laguna Tayabas Bus Company, Inc. A previous Supreme Court decision affirmed an award for lump sum compensation and ordered the company to provide necessary medical services and supplies for Perez's illness. 2. Procedural History: Following the Supreme Court's affirmation of the initial award in G.R. No. L-19522, Tomas Perez filed a motion seeking reimbursement for medical expenses incurred from October 1, 1960, to December 1, 1964, and a supplementary motion for expenses incurred until March 1965. The transportation company opposed this, arguing it had complied by offering to provide medical services through the Buenafe Clinic. The Workmen's Compensation Commission ordered the company to reimburse P3,240.00 for medical expenses, a decision that was upheld upon reconsideration. 3. The Petition: The petitioner, Batangas Laguna Tayabas Bus Company, Inc., seeks review of the Workmen's Compensation Commission's order and resolution. The company argues that the order awarding reimbursement constitutes a modification of the prior Supreme Court decision, which directed the provision of medical services rather than direct reimbursement. They contend they took steps to comply by offering services through the Buenafe Clinic and that the Commission failed to act on their request for an order directing the claimant to report for examination and treatment.
Issue(s)
Whether the order of the respondent Commission requiring the transportation company to reimburse Tomas Perez for medical expenses constitutes a modification of the original decision. Whether the transportation company complied with its obligation under Section 13 of the Workmen's Compensation Act.
Ruling
The Supreme Court affirmed the order and resolution of the respondent Commission. The Court held that the transportation company was liable for reimbursement of the medical expenses incurred by Tomas Perez.
Ratio Decidendi
On the issue of modification of the original decision: The Court found that the order for reimbursement did not constitute a modification of the original decision. The original decision mandated the provision of medical services and supplies. When the employer fails to provide these services promptly, Section 13 of the Workmen's Compensation Act allows the employee to acquire them at the employer's expense. The subsequent order for reimbursement was a consequence of the employer's failure to fulfill its obligation under the original decision, not a modification thereof. The claim was for reimbursement of expenses already incurred, which is a distinct remedy available when the primary obligation to provide services is not met. On the issue of compliance with Section 13 of the Workmen's Compensation Act: The Court ruled that the transportation company did not comply with its obligation. The company's offer to provide medical services through the Buenafe Clinic was made only after the original decision became final and was to be executed. Section 13 requires that such services be provided "immediately after an employee has suffered an injury or contracted sickness and during the subsequent period of disability." The claimant was entitled to these services and supplies from the onset of his sickness and during his disability, not from the date the company belatedly offered them. The claim was for reimbursement of past medical services and supplies already consumed, not for future treatment. Therefore, the employee was justified in acquiring the services at the employer's expense.
Main Doctrine
An employer is liable for reimbursement of medical expenses incurred by an employee if the employer fails to provide the necessary medical services and supplies promptly, as mandated by Section 13 of the Workmen's Compensation Act, and the employee is compelled to acquire them at the employer's expense.