G.R. No. 157168, June 26, 2007
U-BIX CORPORATION, Petitioner, vs. RICHEL BANDIOLA, Respondent.

FACTS

Respondent Richel Bandiola, an employee of petitioner U-BIX Corporation, sustained a fractured leg in a vehicular accident on April 13, 1997, while on his way to a work assignment in Baguio. U-BIX paid for his initial hospitalization at Rosario District Hospital and the Philippine Orthopedic Hospital. However, Bandiola claimed that due to the considerable distance of the Orthopedic Hospital from his Parañaque residence and U-BIX’s subsequent refusal to provide further financial assistance, he sought treatment at Medical Center Parañaque (MCP), incurring expenses for which he presented receipts totaling ₱7,742.50.
Bandiola filed a complaint before the Labor Arbiter for various monetary claims. The Labor Arbiter awarded salary differentials and other benefits but dismissed his claims for medical reimbursement and damages. On appeal, the NLRC modified the decision, ordering U-BIX to reimburse Bandiola for medical expenses and awarding moral and exemplary damages. The Court of Appeals affirmed the NLRC with modification, reducing the reimbursable medical expenses to the receipted amount of ₱7,742.50 and sustaining the awards of ₱25,000.00 in moral damages and ₱25,000.00 in exemplary damages.

ISSUE

Whether the Court of Appeals erred in affirming the awards of actual, moral, and exemplary damages in favor of Bandiola.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. On actual damages, the Court held that an employer has a legal duty to provide immediate medical assistance to an employee injured in the course of employment. U-BIX’s initial payment did not absolve it from reimbursing subsequent necessary medical expenses proven by receipts. Bandiola adequately substantiated his claim with receipts from MCP, justifying the award of ₱7,742.50.
Regarding moral damages, the Court found U-BIX’s refusal to assist Bandiola, who was in dire need of medical treatment for a work-related injury, constituted bad faith. This refusal caused Bandiola physical suffering, mental anguish, and serious anxiety, warranting compensation under Article 2217 of the Civil Code. The award of ₱25,000.00 was deemed proper.
For exemplary damages, the Court ruled that U-BIX’s failure to report the accident to the SSS, as required, and its unjustified refusal to reimburse valid expenses demonstrated a wanton disregard for Bandiola’s welfare. This conduct set a negative example that corrective measures must deter, making the imposition of ₱25,000.00 in exemplary damages legally appropriate.