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

Mariano R. Basa, a retired municipal judge, suffered a heart attack in 1969, leading to his retirement and subsequent award of permanent and total disability benefits.
After nearly six years, he experienced a second heart attack and sought reimbursement for medical expenses related to this incident.
The Labor Department denied his claim, which was affirmed by the Workmen's Compensation Commission, citing that he had already been declared totally and permanently disabled.

The Supreme Court ruled that an employee is entitled to reimbursement for subsequent medical expenses incurred for the same illness after being awarded total and permanent disability benefits.
The decision reversed the Commission's ruling, emphasizing that the right to compensation extends to all medical consequences arising from the primary injury.

The Court highlighted that the Workmen's Compensation Act allows for compensation benefits to cover all medical consequences stemming from a primary injury.
The ruling referenced the case of Enriquez v. Workmen's Compensation Commission, affirming that all medical consequences related to a compensable injury are compensable.

Under Section 13 of the Workmen's Compensation Act, employees have the right to continuous medical treatment and reimbursement for subsequent medical expenses, even after being declared permanently disabled.
This principle was supported by the precedent set in Biscarra v. Workmen's Compensation Commission, which recognized the ongoing obligation of employers to provide medical care.

Justice Teehankee expressed dissent, arguing that once an employee is declared totally and permanently disabled and has received maximum compensation, they should not be entitled to further reimbursement for medical expenses.
He emphasized that the Act does not impose an unlimited obligation on employers to cover ongoing medical expenses for permanently disabled employees.

Justice Teehankee noted that the majority ruling in Biscarra was limited to government employers, leaving unresolved whether private employers would face similar liabilities.
He argued that the financial burden of unlimited medical expenses could lead to bankruptcy for private employers.

Justice Melencio-Herrera reiterated her dissent from Biscarra, asserting that the Workmen's Compensation Act does not entitle permanently disabled employees to ongoing medical services or reimbursement after the initial compensation.
She pointed to the legislative intent to limit compensation to a maximum of P6,000 and the administrative interpretation of the Act by the Workmen's Compensation Commission.