G.R. No. L-43098 March 30, 1981
MARIANO R. BASA, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and REPUBLIC OF THE PHILIPPINES (Department of Justice), respondents.

FACTS

Petitioner Mariano R. Basa, a retired municipal judge, suffered a heart attack in 1969 which forced his retirement. His claim under the Workmen’s Compensation Act was granted in 1970, awarding him permanent total disability benefits and reimbursement for medical expenses incurred. In 1975, approximately six years later, he suffered a second, more severe heart attack. He filed a new claim seeking reimbursement for the medical expenses from this subsequent attack.
The Workmen’s Compensation Unit and, on appeal, the Workmen’s Compensation Commission denied the claim. The Commission reasoned that since the petitioner had already been declared permanently and totally disabled and had received the maximum benefits under Section 15 of the Act, no further claim for reimbursement of subsequent medical expenses could be entertained. The Commission viewed the prior award as final and exhaustive of all liabilities of the employer.

ISSUE

Whether a claimant, already declared permanently and totally disabled and awarded maximum benefits under Section 15 of the Workmen’s Compensation Act, is still entitled to reimbursement for subsequent medical expenses incurred for the same compensable ailment.

RULING

Yes. The Supreme Court reversed the decision of the Workmen’s Compensation Commission. The Court held that the right to medical services and reimbursement under Section 13 of the Act extends beyond the declaration of permanent disability. The legal logic is anchored on the plain language and compassionate purpose of Section 13, which obligates the employer to provide the employee with medical services “immediately after an employee has suffered an injury or contracted sickness and during the subsequent period of disability.”
The Court found that the petitioner’s second heart attack in 1975 was causally linked to his first compensable attack in 1969, as there was no evidence he had fully recovered. Following established doctrine, all medical consequences and sequelae that flow from a primary compensable injury are themselves compensable. The declaration of permanent total disability does not sever this causal chain nor terminate the employer’s obligation for necessary medical care aimed at the employee’s recovery or rehabilitation.
The Court explicitly adopted its recent En Banc ruling in Biscarra vs. Workmen’s Compensation Commission, which held that Section 13 mandates continuous medical treatment. The obligation to provide services “as the nature of his disability and the process of his recovery may require” is ongoing and is not extinguished by a prior lump-sum award for disability. Therefore, the petitioner is entitled to reimbursement for the medical expenses incurred due to the second heart attack, as it was a natural consequence of his original compensable condition.