Case Digest (G.R. No. L-14457)
Facts:
Petitioner Julio Biscarra, a former assistant district forester of the Bureau of Forestry, filed a Notice of Injury or Sickness and Claim for Compensation dated April 4, 1972 for ailments including diabetes mellitus, hypertensive cardiovascular disease, arteriosclerosis, and chronic pyonephritis. The claim was uncontroverted; on May 19, 1972 the Regional Office awarded him P6,000.00 disability compensation for a total and permanent disability, with reservation to claim medical expenses reimbursement. The Regional Office subsequently awarded him P7,183.14 (Order dated September 15, 1972) and later P4,965.41 (decision dated September 24, 1975) for reimbursement of medical expenses.
Respondent Republic of the Philippines (Bureau of Forestry) received the September 24, 1975 decision on September 30, 1975 and filed a petition for relief from judgment on February 4, 1976. On March 10, 1976, the Workmen’s Compensation Commission issued an Order En Banc reversing the decision, disallowing further reimbursement; hence, Biscarra petitioned for review.
Issues:
- Whether the Workmen’s Compensation Commission had jurisdiction to entertain respondent’s petition for relief from judgment filed beyond the reglementary periods.
- Whether a claimant totally and permanently disabled for labor remains entitled to continued reimbursement for medical expenses beyond the disability compensation already paid under Section 13 of the Workmen’s Compensation Act, as amended by Republic Act 4119.
Ruling:
The Court reversed and set aside the Commission’s Order En Banc, and directed the Bureau of Forestry (or its successor) to pay Biscarra P4,965.41 as reimbursement of medical expenses.
On the jurisdictional point, the Court treated respondent’s petition as untimely and held that the Commission should not have disturbed a final and executory decision. On the substantive point, the Court held that Section 13 imposes liability for medical services and supplies during the period of disability without a statutory cap on amount or time, and that the total and permanent nature of disability did not terminate the obligation to provide/ reimburse necessary medical treatment.
Ratio:
The Court ruled that respondent’s petition for relief from judgment was filed beyond the periods stated in Section 3 of Rule 22 of the Commission’s Rules and Regulations, and that once the decision became final and executory, the Commission lacked authority to pass on the merits. The Court cited the established doctrine of finality of judgments and the jurisdictional and mandatory nature of timely appeal/relief, emphasizing that “volume and pressure of work” did not constitute a ground that would justify relief from judgment.
On the merits, the Court interpreted Section 13 liberally in favor of labor and refused to read into the law a limitation that is not expressed. The Court relied on prior rulings sustaining continuous medical care as long as the employee’s condition required treatment, and distinguished disability indemnity limits from the separate and unlimited character of medical benefits under Section 13, as amended, consistent with the constitutional commitment to social justice and just and humane conditions of work.
Doctrine:
- A petition for relief from judgment filed beyond the reglementary periods divests the tribunal of authority to revisit a decision that has become final and executory.
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