🎧 Case Brief Lecture

IRENEO ABELLERA, PETITIONER, VS. SECRETARY OF LABOR AND PHILIPPINE NATIONAL RAILWAYS, RESPONDENTS.

G.R. No. L-45745. August 29, 1988 August 29, 1988

← Read the full text of the decision

Listen, read along, or open presentation mode.

Abellera versus Secretary of Labor and Philippine National Railways

The Case

This is a petition for review on certiorari brought by Ireneo Abellera against the Secretary of Labor and the Philippine National Railways. Abellera, a retired railway employee, sought reimbursement of medical expenses he incurred in 1975 for treatment of ailments contracted during his employment. The Secretary of Labor denied his claim by applying a rule that limited reimbursable medical expenses to a fixed period. The case matters because it fixes the cut-off between the old workmen's compensation regime and the new employees' compensation scheme under the Labor Code, and because it teaches that a claim already accrued under the old law is governed by that old law, not by later implementing rules that cut down the right.

Procedural History

Abellera first filed a claim for compensation benefits with the Workmen's Compensation Section of the Department of Labor in Baguio. The Workmen's Compensation Chief rendered a decision in his favor, awarding compensation benefits, reimbursement of medical expenses, attorney's fees, and administrative costs. The Philippine National Railways appealed to the Workmen's Compensation Commission, but later withdrew its petition for review, so the decision became final and was fully satisfied in 1973.

In December 1975, Abellera wrote to the Chief of the Workmen's Compensation Section asking for reimbursement of a further sum spent at the Bethany Hospital in San Fernando, La Union. Pursuant to the implementing rules of Presidential Decree Number 954, the records were forwarded to the Office of the Secretary of Labor, which denied the claim on the ground that the expenses were incurred beyond the period allowed under those rules. Abellera then filed the present petition for review on certiorari before the Supreme Court.

Facts

Ireneo Abellera was employed by the Philippine National Railways on January 2, 1939 as conductor of the Benguet Auto Line, and was later promoted to traffic inspector. In the course of his employment he was afflicted with ulcer and hypertension. When his ailments worsened, he was confined and treated at the Philippine National Railways Hospital from November 26, 1970 to January 7, 1971, and at the Baguio General Hospital from February 2 to 5, 1971. On May 31, 1971 he stopped working, and on June 1, 1971 he retired under Republic Act Number 4968.

He then filed a claim for compensation benefits. The Workmen's Compensation Chief decided in his favor, awarding compensation benefits, a weekly compensation, reimbursement of medical expenses, attorney's fees, and administrative costs. The company appealed but withdrew its petition, and the decision became final. In September 1973, Abellera fully received the disability benefit due him, including reimbursement of medical expenses incurred from 1971 to 1972.

From September 15, 1975 to December 7, 1975, he was treated at the Bethany Hospital in San Fernando, La Union, spending seven thousand seven hundred forty-eight pesos and forty-seven centavos. On December 10, 1975, he asked for reimbursement of that amount. The Secretary of Labor, applying the implementing rules of Presidential Decree Number 954, held that his right to medical benefits was limited to two hundred eight weeks or to the period covered by the maximum compensation of six thousand pesos, whichever came first. Since his weekly compensation of forty-eight pesos and sixty-nine centavos would exhaust the maximum in one hundred twenty weeks, only expenses from May 31, 1971 to September 20, 1974 were reimbursable. His 1975 expenses fell beyond that period and were denied.

Issues

  • Whether or not the Secretary of Labor correctly applied the implementing rules of Presidential Decree Number 954 in limiting the reimbursable medical expenses of the petitioner.
  • Whether or not the petitioner may still claim reimbursement of medical expenses under the Workmen's Compensation Act, which was the law in force when his cause of action arose.
  • Whether or not such right to reimbursement continues indefinitely into the future under the present law.

Applicable Provisions

Section 2 of Presidential Decree Number 954 provides:

All workmen's compensation cases pending before and duly docketed by the Workmen's Compensation Units in the Regional Offices of the Department of Labor and those pending before and duly docketed by the Workmen's Compensation Commission as of March 31, 1976, shall be processed and adjudicated in accordance with the law, rules and procedure existing at the time their cause of action occurred.

This provision governs which law applies to the petitioner's claim, directing that it be resolved under the law in force when his cause of action arose.

Section 13 of the Workmen's Compensation Act, as discussed in the decision, provides:

Provide the employee with such medical, surgical and hospital services and supplies as the nature of the injury or sickness may require.

This is the old law's obligation on the employer, which the Court holds subsists until the illness is cured or arrested, without any fixed week limit.

Article 185 of the Labor Code provides:

Immediately after an employee contracts sickness or sustains an injury, he shall be provided by the System during the subsequent period of his disability with such medical services and appliances as the nature of his sickness or injury and progress of his recovery may require, subject to the expense limitation prescribed by the Commission.

This is the new scheme, which the Court holds now governs and under which no further claims may be filed under the old Act.

Ruling

On the first issue, the Court found reversible error in the denial of the claim. The application of the rule limiting reimbursable medical expenses was incorrect, because the petitioner's cause of action arose in December 1975, when he was hospitalized and filed his claim, and at that time the Workmen's Compensation Act was the law in force. Under Section 2 of Presidential Decree Number 954, his case had to be adjudicated in accordance with the law existing at the time his cause of action occurred.

On the second issue, the Court ruled that under the old law the employer's obligation to provide medical services subsists until the illness is cured or arrested, so long as it was contracted during employment. This obligation subsisted even if the petitioner was no longer in the employ of the respondent, because the old law did not require the existence of an employer-employee relationship as a condition for the employer's liability. Hence, he may still be paid medical reimbursements.

On the third issue, the Court answered in the negative. The old law has been superseded by the new compensation scheme in the Labor Code, enacted in the belief that it better complies with social justice and is more advantageous to the greater number of working men and women. The Court held that the present law now governs, and no more claims may be filed by the petitioner under the former Workmen's Compensation Act.

Doctrine

A workmen's compensation claim is governed by the law, rules, and procedure existing at the time the cause of action occurred, as expressly directed by Section 2 of Presidential Decree Number 954. Implementing rules that cut down or limit a right already accrued under that law cannot be applied retroactively to defeat the claim. Under the old Workmen's Compensation Act, the employer's obligation to provide medical, surgical, and hospital services and supplies subsists until the illness is cured or arrested, without a fixed week limit, and does not require the existence of an employer-employee relationship. However, that old regime has been superseded by the employees' compensation scheme of the Labor Code, under which medical services are subject to the expense limitation prescribed by the Commission, and no further claims may be filed under the former Act.

Disposition

The Court reversed the decision appealed from and ordered the Philippine National Railways to pay the petitioner seven thousand seven hundred forty-eight pesos and forty-seven centavos as reimbursement for medical expenses, and the Department of Labor and Employment seventy-eight pesos as administrative costs.

Remember This

The single line to memorize is that the law in force at the time the cause of action arose governs the claim, and later implementing rules cannot cut down a right already vested. Examiners use this case to test the transition from the old Workmen's Compensation Act to the Labor Code employees' compensation scheme, and the rule that the employer's duty to provide medical services under the old law subsists until the illness is cured or arrested.