G.R. No. L-19164; February 29, 1964
CEBU PORTLAND CEMENT COMPANY, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and ULDARICO DE LOS REYES, respondents.

FACTS

Uldarico de los Reyes filed a claim for compensation against Cebu Portland Cement Company, alleging he contracted pulmonary tuberculosis due to his work conditions. After a hearing, a decision dated May 26, 1959, declared his illness compensable, having been activated and aggravated by his employment. The company was ordered to pay disability compensation and medical expenses incurred from October 1, 1950, to August 30, 1958. The company failed to appeal, rendering the decision final and executory, and it fully satisfied the award.
Subsequently, on May 20, 1960, de los Reyes filed a petition in the same case for additional medical expenses amounting to P3,821.46, incurred from September 1, 1958, to December 31, 1959, as his tuberculosis treatment was ongoing. After a rehearing, the Hearing Officer ordered the company to reimburse these expenses. The Workmen’s Compensation Commission affirmed this order, prompting the company to elevate the case to the Supreme Court via petition for review.

ISSUE

Whether the employer, Cebu Portland Cement Company, can still be required to pay for medical expenses incurred by the employee after the period covered by a final and satisfied compensation award, specifically for treatment from September 1, 1958, to December 31, 1959.

RULING

Yes. The Supreme Court affirmed the Commission’s order, ruling that the employer remains liable for necessary medical expenses beyond the period initially awarded, as long as the work-connected illness persists and requires treatment. The legal logic hinges on Section 13 of the Workmen’s Compensation Act. Unlike provisions for disability compensation, which have statutory limits, Section 13 imposes an obligation on the employer to provide medical services “as the nature of the injury or sickness may require,” without any textual limitation on duration or amount.
The Court emphasized that workmen’s compensation laws are remedial and should be liberally construed in favor of the employee. Following American jurisprudence, which influenced Philippine law, the absence of a statutory limit means the employer’s liability for medical care continues as long as such services are necessary to cure or relieve the effects of the work-connected injury or sickness. The right to medical attendance ceases only if the employee refuses or obstructs the provided services, which was not alleged here. The compensability of the illness itself was already settled by the final 1959 judgment. Therefore, the claimant’s entitlement to reimbursement for subsequent, proven, and necessary medical expenses was upheld.