G.R. No. L-43534 September 30, 1976
Juan Lopez Manansala, petitioner, vs. Workmen’s Compensation Commission, Republic of the Philippines (Department of Agriculture and Natural Resources, Bureau of Soils), respondents.

FACTS

This case involves petitioner Juan Lopez Manansala’s claim for reimbursement of medical expenses totaling P6,285.00, related to his compensable illnesses of peptic ulcer and tuberculosis contracted during his employment. In a prior Supreme Court decision dated May 30, 1974, the Court remanded the case to the Workmen’s Compensation Commission (WCC) specifically for the reception of petitioner’s proof regarding these medical expenses, emphasizing the Act’s liberal construction in favor of laborers. Pursuant to this remand, the WCC conducted a hearing on August 7, 1974. At this hearing, Dr. Remedios Medina testified and identified a certification from Dr. Juan L. Custodio stating that petitioner incurred P3,126.00 for tuberculosis treatment. For the remaining P3,159.50 for peptic ulcer treatment per Dr. Sisenando Porte’s certification, the commission authorized taking a deposition via written interrogatories through its Davao regional office.

ISSUE

Whether the Workmen’s Compensation Commission committed a reversible error by failing to award reimbursement for the P3,126.00 in medical expenses for tuberculosis treatment, which were duly substantiated by evidence presented at the mandated hearing.

RULING

The Supreme Court granted the petition and ordered the additional reimbursement. The legal logic is straightforward. The Court found that the commission’s decision of March 8, 1976, which awarded only the P3,159.50 for peptic ulcer, completely overlooked the P3,126.00 claim for tuberculosis without any stated justification. The Solicitor General, representing the respondent Republic, admitted this was likely an oversight due to the commission’s hurried disposition of cases before its abolition. Critically, the evidence for the tuberculosis expenses—Dr. Medina’s testimony and the corresponding certification—was presented at the hearing expressly ordered by the Court and was never contested by the respondent. In fact, the Solicitor General had previously expressed agreement with the reasonableness of these expenses. Given that the claim was already fully substantiated in the record and undisputed, the Court ruled that a further remand for proceedings was unnecessary and would only cause undue delay. Applying the principle of liberal interpretation mandated by the Workmen’s Compensation Act to achieve its remedial purpose, the Court corrected the commission’s oversight directly. Accordingly, respondent was ordered to pay petitioner the additional sum of P3,126.00 as reimbursement for medical expenses.