G.R. No. L-30915 July 22, 1975
REPUBLIC OF THE PHILIPPINES (Bureau of Customs), petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and DELFIN MANAHAN, respondents.

FACTS

The claimant, Delfin Manahan, former Chief Accountant IV of the Bureau of Customs, suffered a stroke on November 23, 1967, diagnosed as cerebro-vascular accident secondary to hypertension. He was hospitalized and subsequently received continuous medical treatment and physical therapy. He filed a claim for disability compensation and reimbursement of medical expenses totaling P7,369.30. The Acting Referee awarded the claim, which was affirmed by the Workmen’s Compensation Commission with a modified award of P7,090.60 for medical expenses and P1,309.06 as attorney’s fees.
The Bureau of Customs petitioned for review, contesting the award for medical expenses and the computation of attorney’s fees. The petitioner argued that the claim for medical reimbursement was invalid due to the claimant’s alleged failure to comply with Section 13 of the Workmen’s Compensation Act. This provision requires the attending physician to furnish the employer and the Commission with a report of the injury and treatment within twenty days of the first treatment and every subsequent treatment.

ISSUE

The issues are: (1) whether the claimant’s failure to strictly comply with the reporting requirement under Section 13 of the Workmen’s Compensation Act renders his claim for medical reimbursement unenforceable; and (2) whether the awarded attorney’s fees were correctly computed.

RULING

The Supreme Court affirmed the Commission’s award for medical expenses but modified the attorney’s fees. On the first issue, the Court held there was substantial compliance with Section 13. The records showed the Bureau’s Customs Medical Officer examined the claimant and reported on his condition, including a list of his attending physicians. Furthermore, a certification from the Bureau’s Accounting Division confirmed the claimant’s daughter had notified the Bureau of the projected medical expenses immediately after the illness onset. The petitioner, through its officials, had prompt knowledge of the sickness, the ongoing treatment, and the intent to claim reimbursement. In such a factual setting, where the employer is in a position to obtain necessary information and the failure to strictly comply is not the claimant’s fault, substantial compliance suffices. The award was also supported by receipts.
On the second issue, the Court agreed with the petitioner that the amount awarded for medical expenses should not be included in the computation of the attorney’s fees under Section 31 of the Act. Consequently, the attorney’s fees were reduced to P600.00. The decision was affirmed with this modification.