Title
Basa vs. Workmen's Compensation Commission
Case
G.R. No. L-43098
Decision Date
Mar 30, 1981
Retired judge Basa, declared permanently disabled after a heart attack, sought reimbursement for a second heart attack's medical expenses. The Supreme Court ruled in his favor, citing causal link and continuous medical treatment under the Workmen's Compensation Act.
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Case Digest (G.R. No. L-43098)

Facts:

  1. Initial Heart Attack and Retirement:

    • Mariano R. Basa, a retired municipal judge of Calapan, Oriental Mindoro, suffered a heart attack on July 26, 1969, which incapacitated him from performing his duties. He retired on October 16, 1969.
    • On October 26, 1970, he was awarded permanent and total disability benefits and reimbursement of medical expenses under the Workmen's Compensation Act.
  2. Second Heart Attack and Claim:

    • On January 26, 1975, Basa suffered a second, more severe heart attack, resulting in the loss of speech and physical weakness.
    • On June 26, 1975, he filed a claim for reimbursement of medical expenses related to the second heart attack.
    • The acting chief of the Workmen's Compensation Unit denied the claim on October 14, 1975, reasoning that Basa had already been awarded maximum benefits for permanent and total disability.
  3. Appeal to the Workmen's Compensation Commission:

    • Basa filed a motion for reconsideration, invoking Section 13 of the Workmen's Compensation Act, which provides for continuous medical treatment.
    • On December 27, 1976, the Commission affirmed the denial, stating that no further reimbursement could be awarded after a declaration of permanent and total disability.
  4. Supreme Court Petition:

    • Basa sought review of the Commission's decision, arguing that his second heart attack was causally linked to the first, which had been declared compensable.

Issue:

  • (Unlock)

Ruling:

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Ratio:

  1. Causal Link Between Heart Attacks:

    • The Court found that Basa's second heart attack was causally linked to the first, which had been declared compensable. There was no evidence that Basa had fully recovered from the first heart attack before the second occurred.
    • Medical testimony confirmed that a second heart attack could be a natural consequence of the first, especially in cases of thrombosis.
  2. Continuous Medical Treatment Under Section 13:

    • The Court held that Section 13 of the Workmen's Compensation Act, as amended, imposes an obligation on the employer to provide continuous medical services, appliances, and supplies for as long as the employee's disability persists.
    • The law does not impose a maximum limit on the amount or duration of such medical expenses, and the employer's liability continues until the employee's condition is cured or arrested.
  3. Precedent in Biscarra v. Workmen's Compensation Commission:

    • The Court relied on its earlier decision in Biscarra v. Workmen's Compensation Commission, which held that an employee declared permanently and totally disabled is still entitled to reimbursement for subsequent medical expenses.
    • The Court emphasized that the Workmen's Compensation Act is a social legislation designed to protect workers, and any doubt in its interpretation should be resolved in favor of labor.
  4. Policy Considerations:

    • The Court rejected the argument that continuous reimbursement would impose an intolerable burden on employers, noting that the government, as an employer, could allocate funds for such purposes.
    • The Court highlighted the importance of social justice and compassion in labor cases, particularly for long-serving public servants like Basa.
  5. Dissenting Opinion:

    • Justice Melencio-Herrera dissented, arguing that the Workmen's Compensation Act does not provide for indefinite reimbursement of medical expenses for permanently disabled employees.
    • Justice Teehankee concurred in the result but maintained his dissent in Biscarra, stating that the remedy for such cases lies with legislative action rather than judicial interpretation.

Conclusion:

The Supreme Court ruled in favor of Basa, holding that he is entitled to reimbursement for subsequent medical expenses under Section 13 of the Workmen's Compensation Act, as his second heart attack was causally linked to the first. The Court emphasized the social justice purpose of the Act and the employer's obligation to provide continuous medical treatment for disabled employees.


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