G.R. No. L-45539 August 21, 1980
ALBERTO SALAS, petitioner, vs. REPUBLIC OF THE PHILIPPINES (National Economic Development Authority) and the WORKMEN’S COMPENSATION COMMISSION, respondents.

FACTS

Alberto Salas, a Professional Management Analyst at NEDA, contracted pulmonary tuberculosis in 1969. He filed his first compensation claim (First Case) in February 1974, which was granted by the Acting Referee in June 1974, ordering NEDA to pay disability and medical benefits. NEDA appealed but also voluntarily paid the award. The Workmen’s Compensation Commission later dismissed this First Case in a February 1976 Decision, citing insufficient evidence of disability, a copy of which was received by the Solicitor General in March 1976.
In the interim, Salas returned to work from May to July 1974, after which he retired on medical advice. In January 1975, he filed a second claim (Second Case) for the same ailments, stating he stopped work in July 1974. NEDA did not controvert, noting prior payment. The Acting Referee allowed this second claim in September 1975. NEDA sought review, arguing Salas’s right had been adjudicated in the First Case. The Commission, in a March 1976 Decision, modified but affirmed the award in the Second Case. NEDA’s motion for reconsideration was denied by the Secretary of Labor in an Order dated January 7, 1977, which Salas petitioned to review.

ISSUE

Whether the dismissal of the First Case by the Workmen’s Compensation Commission bars the subsequent award of compensation in the Second Case filed by Alberto Salas.

RULING

The Supreme Court ruled that the second claim is compensable and not barred by the first. The legal logic rests on the principle that a recurrence or reactivation of a compensable illness constitutes a distinct and separate cause of action. The Court found that Salas’s return to work in 1974 and subsequent retirement due to the same ailments created a new period of disability separate from the period claimed in the First Case. The employer, by re-employing a worker with a known history of a compensable disease, assumes the risk of liability for any subsequent disability arising from a recurrence.
The Court dismissed the argument that the Commission’s Decision in the First Case had become final and thus divested jurisdiction over the Second Case. It noted the February 1976 Decision was inconclusive and internally inconsistent, referencing both the first claim and the later-filed second claim. The employer’s voluntary payment for the first period did not extinguish liability for a new and separate period of disability caused by a recurrence. Therefore, Salas was entitled to the maximum disability compensation of P6,000.00 for the second period, as it is a separate entitlement, plus reimbursement for medical expenses. The Order of the Secretary of Labor was set aside, and NEDA was ordered to pay the awarded amounts.