Basa v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Mariano R. Basa, a retired municipal judge, suffered a heart attack in July 1969, leading to his retirement in October 1969. He was awarded permanent and total disability benefits and reimbursement for medical expenses incurred at that time. In January 1975, he suffered a second, more severe heart attack. Procedural History: Basa filed a claim for reimbursement of medical expenses related to his second heart attack with the Department of Labor's Regional Office No. 5. This claim was denied on October 14, 1975, on the grounds that he had already received benefits for permanent and total disability. The Workmen's Compensation Commission affirmed this denial in a decision dated December 12, 1975. The Petition: Basa seeks review of the Commission's decision, arguing that he is entitled to reimbursement for subsequent medical expenses incurred due to his second heart attack, which he contends is a natural consequence of his initial compensable injury. He invokes Section 13 of the Workmen's Compensation Act, as amended, and relies on precedent-setting Supreme Court decisions that allow for continuous medical treatment and reimbursement for subsequent expenses even after a permanent disability award.
Issue(s)
Whether an employee declared permanently and totally disabled under the Workmen's Compensation Act is entitled to reimbursement for subsequent medical expenses incurred for the same disability. Whether the employer's liability for medical expenses under Section 13 of the Workmen's Compensation Act ceases upon the award of permanent and total disability benefits under Section 15.
Ruling
The Supreme Court reversed and set aside the decision of the respondent Commission. The respondent Department (now Ministry) of Justice was ordered to pay the petitioner the sum of P19,880.00 as reimbursement for medical expenses.
Ratio Decidendi
On the entitlement to reimbursement for subsequent medical expenses: The Court held that the petitioner is entitled to reimbursement for subsequent medical expenses. The second heart attack was causally linked to the first, which was already declared compensable. The Court cited Enriquez vs. Workmen's Compensation Commission for the principle that the right to compensation extends to disability due to disease supervening upon and proximately and naturally resulting from a compensable injury. All medical consequences and sequelae flowing from the primary injury are compensable unless an independent intervening cause attributable to the claimant's negligence exists. On the cessation of employer liability upon award of permanent and total disability: The Court ruled that the employer's liability for medical expenses under Section 13 of the Workmen's Compensation Act does not cease upon the award of permanent and total disability benefits under Section 15. The Court, citing Biscarra vs. Workmen's Compensation Commission, emphasized that Section 13 imposes an obligation to provide services, appliances, and supplies as the nature of the disability and the process of recovery may require, and that this law does not provide a maximum limit as to the amount or time for such services. To terminate liability upon declaration of permanent disability would be to add a qualification not found in the law. The Court reiterated that the limitation of P6,000.00 and 208 weeks applies to compensation for disability (loss of wages), not to medical benefits, which are intended to promote early restoration to the maximum level of physical capacity and continue as long as the employee is sick or the disability requires it.
Main Doctrine
An employee declared permanently and totally disabled under the Workmen's Compensation Act is entitled to continuous medical treatment and reimbursement for subsequent medical expenses incurred, as long as the disability requires it, even after the maximum compensation benefits have been paid.