G.R. No. L-40812 April 12, 1982
Recaredo R. Hernando, petitioner, vs. Workmen’s Compensation Commission and Republic of the Philippines (Department of Justice), respondents.

FACTS

The late Arsenia Sauco-Hernando, a Municipal Judge, filed a claim for disability benefits and reimbursement of medical expenses after being diagnosed with work-related illnesses. The Workmen’s Compensation Commission awarded her P6,000.00 for permanent total disability. She died before receiving payment, and her husband, Recaredo Hernando (petitioner), substituted her and was paid the disability award. Subsequently, the petitioner sought reimbursement for medical expenses totaling P28,301.57 incurred for her treatment.
The respondent Commission, however, allowed only P2,913.41 of the claimed amount. It ruled that the employer’s obligation to provide medical services ceased upon the commutation of the lump-sum disability award on March 21, 1973, the date she was declared permanently and totally disabled. The Commission held that any medical expenses incurred after that date were the personal responsibility of the employee or her family, limiting reimbursable expenses only to those incurred from the onset of the illness up to the date of the disability declaration.

ISSUE

Whether the employer’s obligation to reimburse necessary medical expenses under the Workmen’s Compensation Act ceases upon the declaration of the employee’s permanent total disability and the grant of a lump-sum compensation award.

RULING

The Supreme Court reversed the Commission’s decision and ordered the full reimbursement of the claimed medical expenses, provided they were supported by proper receipts. The legal logic is anchored on a clear statutory interpretation. The Workmen’s Compensation Act, as amended, imposes on the employer the obligation to provide the employee with such medical, surgical, and hospital services as the nature of the injury or illness may require. Crucially, the law does not distinguish between medical expenses incurred before and after a formal declaration of disability.
Unlike the provisions for disability compensation, which have monetary and temporal limits, the law does not prescribe a maximum amount or a cutoff period for the reimbursement of necessary medical expenses. The implication is that the employer’s liability for medical services continues for as long as such services are necessary, irrespective of whether the disability has been adjudged as permanent and total. The Court, citing precedent (Cebu Portland Cement Company vs. Workmen’s Compensation Commission), emphasized that the right to medical attendance is separate from and supplementary to the right to disability compensation. The grant of a lump-sum disability award does not extinguish the separate and continuing obligation to defray necessary medical costs arising from the work-connected ailment. The Act is a social legislation designed for the workman’s relief and must be liberally construed in his or her favor.