G.R. No. L-42873. January 22, 1980.
ANASTACIA N. PARMISANO, petitioner, vs. THE WORKMEN’S COMPENSATION COMMISSION, and REPUBLIC OF THE PHILIPPINES (Bureau of Public Schools), respondents.

FACTS

Anastacia N. Parmisano, a clerk for the Bureau of Public Schools, sustained a crushing injury with a compound comminuted fracture from a motor vehicle accident in the course of her employment on January 24, 1966. This injury necessitated the amputation of her right leg above the knee. She was awarded disability benefits on April 12, 1966, with a reservation for any claim for medical expenses. An initial claim for medical reimbursement was granted on November 21, 1967, awarding her P665.25.
On October 7, 1974, Parmisano filed a subsequent claim for reimbursement of expenses totaling P5,578.65, incurred for her rehabilitation. These expenses, not included in her prior claim, covered the acquisition of an artificial leg and the necessary fitting and training for its use. The Acting Referee at the Regional Office awarded a reduced amount of P2,225.00 based on a medical evaluation. The Bureau of Public Schools appealed to the Workmen’s Compensation Commission.

ISSUE

Whether the claimant is entitled to reimbursement for expenses related to the acquisition of an artificial leg and rehabilitation training, despite a prior award for disability and an earlier reimbursement for medical expenses that did not expressly reserve the right to claim such subsequent rehabilitation costs.

RULING

The Supreme Court ruled in favor of the petitioner, Anastacia Parmisano. The Court set aside the decision of the Workmen’s Compensation Commission and reinstated the award of P2,225.00 for rehabilitation expenses.
The legal logic centers on the mandatory and continuing nature of the employer’s duty under Section 13 of the Workmen’s Compensation Act. This provision obligates the employer to provide the employee with all necessary “medical, surgical and hospital services and supplies” required by the nature of the injury, immediately after its occurrence and during the subsequent period of disability. The Court interpreted “services and supplies” expansively to include not just immediate treatment but also essential appliances and rehabilitation necessary for the employee’s recovery and adjustment. This encompasses the acquisition of artificial members, like an artificial leg, and the indispensable fitting and training in their use.
The Commission’s reversal, based on the grounds that the prior permanent partial disability award had been fully evaluated and that the earlier reimbursement order contained no express reservation for further claims, was erroneous. The Court clarified that the employer’s statutory duty to provide necessary services and supplies is not extinguished by a prior disability award. Rehabilitation expenses, such as those for a prosthetic limb and training, are a distinct and necessary component of the medical services mandated by law, arising directly from the work-connected injury. The right to these benefits is inherent in the statute and is not contingent upon an express reservation in a previous order. Therefore, the claimant is entitled to reimbursement for these vital rehabilitation costs.