GR 175773; (June, 2013) (Digest)
G.R. No. 175773; June 17, 2013
MITSUBISHI MOTORS PHILIPPINES SALARIED EMPLOYEES UNION (MMPSEU), Petitioner, vs. MITSUBISHI MOTORS PHILIPPINES CORPORATION, Respondent.
FACTS
The parties had a Collective Bargaining Agreement (CBA) wherein the company would shoulder hospitalization expenses for dependents of covered employees, subject to limitations. Employees contributed a monthly premium via salary deduction. When the CBA expired, a new one with increased benefits was executed. Three union members filed claims for their dependents’ hospitalization expenses. In each case, a portion of the expenses had been paid by the dependent’s own health insurance provider (MEDICard in two cases, Prosper in one). Respondent Mitsubishi Motors Philippines Corporation (MMPC) paid only the remaining balance of the expenses not covered by these other insurers, refusing to pay the amounts already shouldered by them. The union insisted employees were entitled to the full, undiminished amount of hospital expenses as per the CBA. The dispute was brought to a Voluntary Arbitrator, who ruled in favor of the union. The Court of Appeals reversed this decision.
ISSUE
Whether the hospitalization benefits under the CBA should be paid in full without deduction for amounts already paid by the dependents’ other health insurance providers.
RULING
The Supreme Court DENIED the petition and AFFIRMED the Court of Appeals’ Decision. The company is not obligated to pay hospitalization expenses already covered by other insurance. The CBA provision creates a contract of indemnity, not a gratuity. The right to reimbursement is limited to the actual loss incurred. Allowing recovery of amounts already paid by other insurers would constitute unjust enrichment, violating the principle of indemnity. The payments from other health insurance are considered benefits from a “collateral source,” which do not reduce the liability of the obligor (MMPC) for the loss. However, this “collateral source rule” is not absolute and yields to the superior principle of preventing unjust enrichment. Since the employees’ dependents suffered no loss for the amounts already paid by their other insurers, the company’s obligation to indemnify for those amounts is extinguished. The union’s claim for full reimbursement, despite the absence of actual loss for a portion, has no basis.