Case Digest (G.R. No. L-29349)
Case Digest (G.R. No. L-29349)
Facts:
This is Franklin Baker Company of the Philippines v. Florencio Diamante and Workmen's Compensation Commission, G.R. No. L-29349, November 21, 1979, the Supreme Court First Division, Fernandez, J., writing for the Court.Petitioner Franklin Baker Company of the Philippines employed Florencio Diamante as a sheller; Diamante contracted pulmonary tuberculosis (PTB) and filed a claim docketed as RO5-WC Case No. 140. An Associate Commissioner (Sanchez) rendered a decision on December 19, 1962 declaring the illness compensable and directing the employer to provide necessary medical services until the ailment was arrested or cured; the Workmen’s Compensation Commission (WCC) en banc sustained that decision on January 15, 1963.
The company satisfied the award of weekly compensation and paid Diamante for 208 weeks, the period prescribed, which terminated on September 4, 1963; petitioner reported such satisfaction on September 13, 1963. Diamante thereafter sought an extension of the period of compensation (petition filed October 8, 1963), and the Commission, by order dated November 6, 1963, extended compensation provided the total did not exceed P4,000. That extension was later upheld by this Court in G.R. No. L-22206 (October 31, 1967).
While proceedings were pending, Diamante filed a motion for reimbursement of medical expenses in November 1963 (annexed receipts from Brion Clinic), which was initially dismissed by Commissioner Cesareo Perez; Diamante filed a motion for reconsideration (dated January 3, 1966) and petitioner filed an opposition (January 12, 1966). The WCC en banc granted the motion for reimbursement in a resolution dated July 16, 1968, ordering reimbursement of P1,275.00 for medical expenses. Petitioner invoked this Court’s review of the WCC order; the petition challenges (1) the Commission’s authority to grant reimbursement after the award had been satisfied and (2) the Commission’s alleged summary action without a hearing.
Issues:
- Did the Workmen’s Compensation Commission have authority to grant Diamante’s motion for reimbursement of medical expenses after the original award had been satisfied and the case terminated?
- Did the Commission violate due process by granting the motion for reimbursement without a formal hearing?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)