G.R. No. L-29703 February 25, 1971
REPUBLIC OF THE PHILIPPINES (BUREAU OF PUBLIC SCHOOLS), petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and FERNANDO P. ALDABA, ET AL., respondents.

FACTS

Leonor M. Aldaba, a public school teacher in San Teodoro, Oriental Mindoro, for nearly fifteen years, died on March 9, 1967. On January 10, 1967, while conducting a physical education class, she was caught in the rain. She later developed severe headaches and fever. Despite treatment from the municipal health physician, she continued working intermittently until her condition worsened. She was diagnosed with pneumonia in Calapan and was later confined in Manila and at the Rizal Provincial Hospital, where she died. The certified cause of death was “pulmonary edema and cerebral edema.” Her husband, Fernando P. Aldaba, filed a claim for death compensation benefits, burial, and medical expenses on behalf of himself and their minor children.
The employer, the Bureau of Public Schools, initially indicated it would not controvert the claim in its filed “Employer’s Report of Accident or Illness.” However, the Office of the Solicitor General later expressed an intention to controvert. The acting referee and subsequently the Workmen’s Compensation Commission awarded the claims. The Republic, through the Bureau of Public Schools, appealed, arguing that the right to reimbursement for medical expenses is personal and extinguished upon death, and that the claimants failed to comply with the reporting requirement under the law.

ISSUE

The primary issues were: (1) Whether the right to reimbursement for medical expenses incurred by the deceased employee is extinguished upon her death; and (2) Whether the claim for medical benefits is invalid for alleged non-compliance with the statutory reporting requirement.

RULING

The Supreme Court affirmed the Commission’s decision, rejecting both of the petitioner’s arguments. On the first issue, the Court held that the right to reimbursement for medical expenses is not purely personal and is transmitted to the legal heirs upon the employee’s death. The Workmen’s Compensation Act imposes a duty on the employer to provide necessary medical services and supplies. The law allows an employee to acquire these at the employer’s expense if not promptly furnished, creating an unqualified right to reimbursement. The Court found no legal provision stating this right is extinguished upon death, and rights of action generally pass to heirs unless explicitly personal by law.
On the second issue, the Court found the claim for medical benefits valid. The employer had actual knowledge of Aldaba’s illness, treatment, and death, as her school principal and division superintendent attended her funeral. The employer failed to file the required report within the statutory period after gaining knowledge of the disability. Furthermore, by initially stating in its report that the claim would not be controverted, the employer is deemed to have renounced its right to challenge the claim. The Commission correctly held that the employer’s knowledge constituted substantial compliance with the reporting requirement, and the supported medical expenses were reasonable and reimbursable. The appeal was dismissed.