G.R. No. L-42337 October 9, 1978
ROSITA S. SUARNABA, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and CLAVECILLA RADIO SYSTEM, respondents.

FACTS

Petitioner Rosita S. Suarnaba filed a claim for death benefits and medical reimbursement following the death of Ireneo Suarnaba, an employee of private respondent Clavecilla Radio System. The Acting Referee of the Regional Office awarded the claim. Upon review, the Workmen’s Compensation Commission sustained the compensability of the death but disallowed the award. The Commission held that petitioner failed to submit sufficient proof to establish she was the legal widow of the deceased, deeming the evidence on record inadequate.
The Commission specifically found the certification from the Assistant Parish Priest of Sta. Barbara, Iloilo, which attested to the solemnization of marriage between petitioner and Ireneo on May 19, 1931, as insufficient to prove legal filiation. It ruled this document was merely proof of a marriage sacrament, not authentic proof of a legal marital relationship. Consequently, the Commission barred petitioner from recovering benefits, instead ordering the employer to pay a sum to the Workmen’s Compensation Fund.

ISSUE

Whether the Workmen’s Compensation Commission committed grave abuse of discretion in ruling that petitioner failed to prove she was the legal wife and dependent of the deceased employee, Ireneo Suarnaba.

RULING

Yes. The Supreme Court granted the petition and set aside the Commission’s decision, reinstating the referee’s award with a modification on attorney’s fees. The Court found the Commission’s conclusion was contrary to the evidence and constituted grave abuse of discretion.
The legal logic is clear. First, the employer itself, through its General Manager, admitted in the “Employer’s Report of Accident and Sickness” that petitioner Rosita Suarnaba was the wife and a dependent of the deceased. This admission, serving as the employer’s answer, established her status without need for further proof. Second, corroborative evidence existed: the Notice and Claim for Compensation filed by petitioner as the wife, the Certification of Death listing her as the surviving spouse, and an affidavit from a witness stating petitioner lived with the deceased and collected his salary. Third, the parish certification, which the Commission acknowledged as proof of the solemnization of the marriage sacrament, was valid evidence. Finally, a legal presumption exists that a man and woman conducting themselves as husband and wife are legally married. All this evidence, viewed in light of the Workmen’s Compensation Act as a social legislation to be liberally construed in favor of the laborer and dependents, overwhelmingly established petitioner’s rightful claim as the legal dependent widow. The Commission’s disregard of this constituted reversible error.