Title
Biscarra vs. Republic
Case
G.R. No. L-43425
Decision Date
Jan 22, 1980
A retired forester, declared totally disabled, sought reimbursement for medical expenses. The Supreme Court ruled that employers must cover ongoing medical costs for permanent disabilities, emphasizing social justice and finality of judgments.
disabled employee
lifelong medical benefits
diabetes mellitus

Case Summary (G.R. No. L-43425)

Factual Background and Medical Expense Claims

Petitioner filed a Notice of Injury or Sickness and Claim for Compensation dated April 4, 1972. He alleged that, due to his ailments, he stopped working and retired at age fifty-eight on October 31, 1970. The claim for disability compensation was not controverted. On May 19, 1972, the Regional Office issued an award granting P6,000.00 as disability compensation, after declaring petitioner totally and permanently disabled for labor, with a reservation allowing petitioner to seek reimbursement of medical expenses. Petitioner then filed a claim for reimbursement of medical expenses with the same Regional Office. By Order dated September 15, 1972, the Regional Office awarded P7,183.14 as reimbursement. On January 3, 1975, petitioner filed another petition for reimbursement of medical expenses incurred thereafter. By decision dated September 24, 1975, the Regional Office again granted P4,965.41 as reimbursement. Petitioner’s medical expense reimbursement decision was received by the Republic on September 30, 1975.

Republic’s Petition for Relief from Judgment and the WCC’s En Banc Action

Instead of filing a seasonable appeal, respondent Republic filed on February 4, 1976 a petition for relief from judgment, dated January 29, 1976, with the WCC. It attributed the delay in acting on the decision to the “volume and pressure of work” of the trial attorney and argued that petitioner was not entitled to further reimbursement of medical expenses after he had been declared totally and permanently disabled for labor. On March 10, 1976, the WCC issued the questioned Order En Banc, reversing the Regional Office’s September 24, 1975 decision. The WCC held that the September 24, 1975 decision should be set aside because petitioner had been declared totally and permanently disabled and no amount of medical treatment could restore him to his former physical capacity for labor; it further concluded that it would be unfair for respondent to continuously pay medical expenses, characterizing petitioner’s prior award as the “maximum amount” of P6,000.00 under the Act, and thus denying any additional reimbursement.

Petitioner’s Arguments on Finality and Statutory Interpretation

Petitioner contended that the September 24, 1975 decision awarding medical expense reimbursement had already become final and executory when respondent filed its petition for relief from judgment. He relied on the record and emphasized that respondent did not seasonably appeal. He maintained that, instead, respondent filed its petition for relief based on the cited ground after an elapsed period of one hundred twenty-seven days from receipt of the decision, which was allegedly beyond the periods prescribed in Section 3 of Rule 22 of the WCC’s Rules and Regulations, namely within thirty days from knowledge and within three months from entry. Petitioner argued that, absent a timely petition for relief from judgment favorably acted upon by the WCC, it would have lacked jurisdiction to pass on the merits because the decision had already attained finality. He further contended that the ground invoked—“volume and pressure of work”—did not constitute mistake or excusable negligence sufficient to justify relief from judgment, since such circumstance had been consistently held not to warrant relief available only in exceptional cases.

Issue on Scope of Medical Benefits Under Section 13 of the Workmen’s Compensation Act

Beyond the jurisdictional and finality issues, the Court addressed the “transcendental” question whether a claimant totally and permanently disabled remained entitled to continued hospital and medical services and further reimbursements of medical expenses, despite having received the disability compensation maximum. Petitioner asserted that Section 13 of the Workmen’s Compensation Act, as amended, imposed no limit on the employer’s obligation to reimburse medical expenses as long as the ailment was not arrested or cured. He argued that, despite prior reimbursement of P7,183.14, he was still entitled to reimbursement of additional medical expenses of P4,965.41 due to further necessary treatment for his work-connected ailments. Petitioner also argued that the defense raised by the Republic in its petition for relief from judgment was available earlier and should have been pleaded or raised during the Regional Office proceedings; therefore, respondent was allegedly estopped from raising it belatedly.

Respondent, through the Office of the Solicitor General, countered that it was not liable for additional medical expenses because once petitioner had been paid full disability compensation, its liability for further medical services had already terminated. Respondent argued that granting further medical expenses for a totally and permanently disabled claimant who had been fully compensated would unduly stretch the employer’s obligations under Section 13 and would produce an absurd and endless obligation not contemplated by law.

Statutory Text and Prevailing Construction of Section 13

The Court focused on Section 13, emphasizing that it required the employer or insurance carrier to provide, immediately after an employee suffered an injury or contracted sickness and during the subsequent period of disability, the services, appliances, and supplies the nature of the disability and the process of recovery might require and those that would promote early restoration to the maximum level of physical capacity. The Court underscored that Section 13 did not provide a maximum amount or specify a time limit for the right to medical benefits. The majority reasoned that to deny continued medical reimbursement on the premise that total and permanent disability terminates the medical obligation would effectively add a qualification not found in the statute and would thereby constitute judicial legislation.

The Court contrasted the amended provision with the earlier text before amendments, noting that previously the employer’s pecuniary liability for medical, surgical, and hospital services had been limited to an amount ordinarily paid in the community. It stated that after the 1964 amendment through Republic Act 4119, the statutory framework no longer contained a maximum either in amount or time, thereby supporting an interpretation of continuing liability as long as medical services and treatment were required by the ailment in the context of disability.

Review of Jurisprudence on Continuing Medical Benefits

The majority reiterated that it had previously held that, under the earlier statutory language as amended prior to 1964, medical attendance could subsist during the period of disability and lasted as long as the employee was sick. It cited La Mallorca-Pambusco vs. Isip (October 19, 1961), where the Court upheld continuing medical and hospital services until illness was cured or arrested, and clarified that limits applicable to disability compensation did not apply to medical attendance because medical care was governed by Section 13. It then cited Itogon-Suyoc, Inc. vs. Fruto Dulay (September 31, 1963), reiterating that the limit of disability compensation durations did not restrict medical care, which lasted during the period of disability. It further cited Cebu Portland Cement Co. vs. WCC (February 29, 1964), holding that Section 13 imposed an obligation without any maximum time or amount limitation on medical attendance and charging that medical benefits were meant to continue as necessary to cure or relieve, consistent with the humane and remedial character of compensation legislation.

The Court further relied on the general line of cases where medical benefits were granted even where claimants continued working despite the ailments, treating these benefits as independent from wage-loss disability compensation. It cited Corales vs. ECC and GSIS (February 27, 1979) as an example of reviewing earlier decisions and interpreting medical benefits as payable regardless of whether the illness resulted in wage-loss or disability compensation, reasoning that Section 13 commanded medical services during the subsequent period of disability even if an employee continued to report to work until retirement.

The Court rejected respondent’s attempt to limit medical services solely by reference to the “totally and permanently disabled” status and the idea of termination due to incurability. It held that findings of total and permanent disability were not conclusive proof that further treatment could not relieve the employee from pain or injurious effects. In support, it invoked the principle from W.J. Newman Co. vs. Industrial Commission that, even where cure is impossible, continued medical services may still be reasonably required to relieve effects of injury.

Majority Reasoning Anchored on Social Justice and Remedial Purpose

The majority treated the employer’s obligation for medical services as not dependent on an employee’s ability to return to work. It treated disability compensation and medical benefits as covered by separate provisions. It held that disability compensation involved wage-loss considerations and statutory ceilings, while medical benefits under Section 13 were not fixed as to duration or amount. It reasoned that if a claimant is denied continuing medical and hospitalization after a finding of total and permanent disability, then disabled employees would paradoxically receive fewer rights than those temporarily incapacitated under the same remedial scheme.

The majority further anchored its interpretation on the constitutional and statutory mandate of social justice, stressing the welfare-state character of labor legislation and the directive that doubts in labor matters be resolved in favor of labor. In its discussion, it referenced constitutional provisions and the later statutory policies of the New Labor Code, particularly provisions on medical services and rehabilitation services, to reinforce the legislative direct

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