G.R. No. L-38184. May 30, 1974.
Juan Lopez Manansala, petitioner, vs. Republic of the Philippines (Department of Agriculture and Natural Resources, Bureau of Soils), and Workmen’s Compensation Commission, respondents.

FACTS

Petitioner Juan Lopez Manansala, a mechanic-driver for the Bureau of Soils, filed a claim for disability compensation on June 9, 1971, due to tuberculosis and peptic ulcer contracted during his employment. The claim was not controverted by the Bureau of Soils and the Office of the Solicitor General, who admitted its validity. Initially, the Regional Office denied the claim, finding the petitioner had not been absent for more than three days from 1965 to 1971. Upon review, the Workmen’s Compensation Commission reversed this, noting evidence of confinement at the Quezon Institute from May 18 to 27, 1966.
The Commission awarded the petitioner temporary total disability benefits and non-scheduled disability compensation totaling P1,147.05 under Sections 14 and 18 of the Workmen’s Compensation Act. However, it denied his separate claim for reimbursement of medical expenses amounting to P6,285.50 under Section 13. The denial was based on the grounds that the claim was “not supported by the receipts nor substantiated by the testimony of the attending physician,” despite medical certificates from two doctors specifying expenses and an indorsement from the Solicitor General agreeing the amount was fair and reasonable.

ISSUE

Whether the Workmen’s Compensation Commission acted with grave abuse of discretion in denying the petitioner’s claim for reimbursement of medical expenses.

RULING

The Supreme Court held that the Commission erred and reversed its denial. The legal logic centers on the Commission’s failure to exercise its broad statutory powers liberally in favor of the worker, as mandated by the Workmen’s Compensation Act’s objective to provide relief and prevent dependency on charity. Four key circumstances underscored this error. First, the Commission itself recognized the petitioner’s entitlement to reimbursement, yet denied him the opportunity to formally adduce proof of his expenses. Second, the underlying disability claim was non-controverted and admitted as valid by the government respondents. Third, medical certificates from attending physicians already specified the incurred expenses. Fourth, and crucially, the Office of the Solicitor General, representing the employer, expressly indorsed that the claimed amount was “fair and reasonable” and was not being contested.
Given these combined circumstances, the outright denial constituted a failure to comply with the Act’s directive for a liberal construction in favor of the employee. The Court ordered the case remanded to the Commission solely for the reception of the petitioner’s proof regarding the medical expenses and for further appropriate proceedings. No costs were awarded.