G.R. No. L-43098 - Basa vs. Workmen's Compensation Commission

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)
Legal Reasoning Model

Facts:

Background of the Petitioner

Mariano R. Basa, a retired municipal judge of Calapan, Oriental Mindoro, served from 1947 until his retirement in October 1969.

He suffered his first heart attack on July 26, 1969, which rendered him incapacitated and forced him to retire.

Following his retirement, he filed a claim under the Workmen’s Compensation Act and, in October 1970, was awarded permanent and total disability benefits along with reimbursement of the medical expenses incurred at that time.

The Second Heart Attack and Subsequent Medical Claims

On January 26, 1975, after nearly six years from the initial attack, the petitioner experienced a second, more severe heart attack.

This second episode resulted in a significant decline in his health, including a loss of power of speech and further weakening of his bodily functions.

On June 26, 1975, he filed with the Workmen’s Compensation Unit of the Department of Labor, Regional Office No. 5 at San Pablo City a claim for reimbursement of the medical expenses incurred relating to this second event.

On October 14, 1975, the acting chief of the unit denied the claim on the grounds that he had already been awarded benefits under Section 15 for permanent and total disability, which included reimbursement of his initial medical expenses.

Proceedings and Contentions

Petitioner filed a motion for reconsideration invoking Section 13 of the Workmen’s Compensation Act, as amended.

The Workmen’s Compensation Commission, in its December 27, 1976 decision, reaffirmed the denial by stating that the subsequent claim was merely an attempt to obtain additional reimbursement for benefits already accorded under the permanent and total disability award.

The parties agreed that the primary issue was whether a claimant, already declared totally and permanently disabled and having received maximum benefits under Section 15, is entitled to recover further reimbursement for additional medical expenses incurred from a subsequent heart attack.

Detailed Financial Breakdown of the Claim

Petitioner’s claim, initially stated as P20,588.85 through his letter to the Workmen’s Compensation Unit, was supported by submitted receipts totaling P19,880.00.

Hospital charges (including amounts reflected in several exhibits) amounted to P11,750.00.

Additional professional fees were evidenced by receipts for services rendered by Dr. Gatchalian (P6,500.00), Dr. Quizon (P300.00), and Dr. Damian (P1,000.00).

Context of the Dispute

The essential dispute centered on whether the petitioner’s second heart attack, causally related to the first, qualifies for further reimbursement under Section 13 despite the prior award for total disability.

The case raised important questions about the extent of the employer’s (or state’s) duty to provide continuous medical benefits beyond the initial award.

Issue:

Whether the petitioner, already declared totally and permanently disabled and having received maximum compensation under Section 15, is entitled to recover additional reimbursement for subsequent medical expenses incurred from his second heart attack.

Whether the causal relationship between the first and second heart attacks qualifies the petitioner for further benefits under Section 13 of the Workmen’s Compensation Act, which mandates continuous medical services during the period of disability.

Ruling:

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Ratio:

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Doctrine:

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