Title
Franklin Baker Company of the Philippines vs. Diamante
Case
G.R. No. L-29349
Decision Date
Nov 21, 1979
Florencio Diamante, a sheller, contracted work-related PTB, won compensation, and later sought reimbursement for medical expenses. The Supreme Court upheld the WCC's authority to grant reimbursement without a formal hearing, affirming it as a corollary to the original compensation claim.
medical expenses
compensable illness
reimbursement
A

Case Summary (G.R. No. L-29349)

Procedural and Compensation History

Diamante filed a compensation claim for pulmonary tuberculosis, which was docketed as RO5-WC Case No. 140. After hearing, an initial decision awarded benefits to the claimant. The petitioner appealed until the matter reached the Commission en banc, which affirmed the Referee’s decision. The petitioner ultimately satisfied the award by paying Diamante weekly compensation benefits for 208 weeks, with the period ending on September 4, 1963, and it reported compliance on September 13, 1963.

The Extension Proceeding and Related Supreme Court Decision

After the satisfaction of the original award, Diamante filed a petition for extension of period of compensation on October 8, 1963, alleging, among other matters, that he was still under treatment by the company physician. This extension proceeding became the subject of a prior petition for review before the Supreme Court (G.R. No. L-22206), which was decided in Diamante’s favor. Meanwhile, the Workmen’s Compensation Commission issued an order dated November 6, 1963 extending the period of compensation beyond 208 weeks, subject to the limitation that the compensation would not exceed P4,000.00. The Supreme Court later affirmed this approach in its decision promulgated on October 31, 1967, reasoning that once the employer had paid compensation in accordance with the Commission’s decision, the question of compensability was no longer open, and formal hearing was not necessary where further medical assistance and continued incapacity justified extension under the Commission’s authority.

The Reimbursement Motion and Its Resolution

During the pendency of the Supreme Court petition on the extension of compensation, Diamante filed, on November 8, 1963, a motion for reimbursement of medical expenses. The motion was subsequently dismissed by the then Commissioner Cesareo Perez, and Diamante filed a motion for reconsideration. The petitioner opposed the motion for reconsideration, asserting that the original decision had long become final and that it had already been satisfied, with no mention of medical expenses, and that the matter was at most a forgotten evidence not proper to reopen the case.

Despite the opposition, the Workmen’s Compensation Commission en banc granted the motion for reimbursement in a resolution dated July 16, 1968, awarding Diamante P1,275.00 for medical expenses. The petitioner then filed the present petition for review, assigning two errors: (1) the Commission’s lack of authority to grant reimbursement after finality and satisfaction of judgment, and (2) the Commission’s alleged summary grant without the benefit of a hearing.

The Petitioner's Position on Authority and Due Process

The petitioner maintained that the Workmen’s Compensation Commission no longer had authority to grant reimbursement after the main compensation case had already been decided, terminated, and satisfied, and after the judgment had become final. It also argued that the Commission committed reversible error by granting the motion for reimbursement without conducting a hearing, implying a denial of due process.

The Court’s Assessment of the Nature of the Reimbursement Claim

The Court rejected the petitioner’s insistence on lack of authority. It held that the reimbursement sought was not a new claim for disability compensation. Instead, it was treated as a corollary to the Commission’s existing determination that Diamante’s illness remained work-connected and therefore compensable, particularly in relation to the obligation to provide medical services. The Court stressed that in Case No. 140, the decision of Associate Commissioner Sanchez dated December 19, 1962 required the petitioner to provide necessary medical services until Diamante’s PTB was arrested or cured as a corollary to the finding of compensability. That decision was sustained by the Commission en banc in a resolution dated January 15, 1963.

The Court also linked the reimbursement to the Commission’s later extension order and the Supreme Court’s earlier affirmance in the extension case. It noted that after the 208-week compensation award had been paid, the Commission could still reopen matters to manage continuation through the statutory mechanism for extension. In G.R. No. L-22206, the Court had held that an award of compensation already satisfied may be reopened on petition for extension, and that a period for payment that has already expired may still be extended, provided statutory limits are observed. This framework supported the Commission’s action as an implementation of its duty regarding medical services arising from the compensable illness.

The Court’s Examination of Procedural Regularity and Opportunity to Contest

On the allegation that the Commission acted summarily and without a hearing, the Court found no reversible error. It emphasized that the reimbursement motion was filed while the earlier Supreme Court petition was pending, and that in granting reimbursement, the Commission was implementing its decision in Case No. 140, which directed the petitioner to furnish the claimant the necessary medical services. The record showed that the petitioner was furnished a copy of the motion for reimbursement, and it was also given access to the receipt of the Brion Clinic evidencing the P1,275.00 expense for medicine and medical fees.

The Court further observed that the petitioner received copies related to the reconsideration process. The petitioner was furnished a copy of the claimant’s motion for reconsideration dated January 3, 1966, and the petitioner itself filed an opposition dated January 12, 1966 to that reconsideration. From these circumstances, the Court held that the petitioner had been afforded sufficient opportunity to question and contest the underlying reimbursement evidence and did not suffer a denial of due process.

Reliance on Controlling Precedent on Reimbursement of Medical Expenses

To bolster its ruling, the Court cited a similar case involving the same parties where reimbursement for medical expenses was allowed. In that earlier controversy, the Supreme Court had applied Section 13 of the Workmen’s Compensation Act and explained that the law entitles the employee to necessary services promptly, and that if the employer cannot furnish them promptly, the employee may acquire them at the employer’s expense. The Court in that precedent characterized the claim as reimbursement for past medical services already received and

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