GR L 43665; (July, 1979) (Digest)
G.R. No. L-43665. July 30, 1979.
AMPARO S. JOCOBA, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION AND THE REPUBLIC OF THE PHILIPPINES (BUREAU OF PUBLIC SCHOOLS), respondents.
FACTS
Petitioner Amparo S. Jocoba, a public school teacher in Siasi, Sulu, contracted a work-connected illness. She was hospitalized during a school vacation, which allowed her to continue teaching without interruption during the regular school year. A Division Committee report from the Bureau of Public Schools confirmed her illness was work-related. Consequently, she filed a claim for reimbursement of medical expenses with Regional Office No. 10 in Zamboanga City.
The Hearing Unit of the regional office awarded her P1,999.66 based on the evaluation of its Compensation Rating Officer and supporting receipts. The respondent Bureau of Public Schools appealed to the Workmen’s Compensation Commission (WCC). The WCC, while affirming the compensability of her illness and her entitlement to reimbursement, reduced the award to P596.30 without providing any explanation for the reduction, relying only on the findings of its Chief of the Evaluation Commission.
ISSUE
Whether the Workmen’s Compensation Commission acted with grave abuse of discretion in arbitrarily reducing the award for medical reimbursement without justification.
RULING
Yes. The Supreme Court set aside the WCC’s order and reinstated the original award. The legal logic is straightforward. First, the compensability of the illness and the claimant’s right to reimbursement were uncontested, as expressly recognized by the WCC itself. The Court cited the WCC’s own statement that reimbursement is allowable under the law even when no disability compensation is granted, as expenses were factually incurred for a work-connected ailment.
Second, and crucially, the reduction of the award from P1,999.66 to P596.30 was arbitrary. The WCC failed to provide any rationale for disregarding the detailed evaluation of the regional office’s Compensation Rating Officer and the supporting receipts. In the absence of a clear explanation or contrary evidence, the initial award based on the medical officer’s evaluation and documentary proof must be upheld as reasonable. The Court emphasized that administrative bodies must exercise their power judiciously and with due process; a mere unilateral reduction without justification constitutes grave abuse of discretion. Therefore, the respondent Bureau was ordered to pay the full P1,999.66 as originally adjudged.