G.R. No. L-44653. May 31, 1977.
CATALINA V. VDA. DE LABUCA, petitioner, vs. WORKMEN’S COMPENSENT COMMISSION and REPUBLIC OF THE PHILIPPINES (Bureau of Public Schools), respondents.

FACTS

Petitioner Catalina V. Vda. de Labuca, claiming to be the widow of the late Domingo Labuca, filed a claim for death benefits under the Workmen’s Compensation Act. Domingo Labuca had been employed as a public school teacher by the respondent Bureau of Public Schools from 1938 until his death on March 6, 1973, due to pulmonary tuberculosis, an illness contracted during his employment. The respondent Republic failed to controvert the claim on time. The Acting Referee awarded benefits to petitioner.
Upon appeal by the Bureau, the Workmen’s Compensation Commission sustained the compensability of the death but denied payment of benefits to Catalina. The Commission held that the record lacked evidence to prove she was the legal wife of the deceased. It specifically discounted a certificate of marriage issued by a parish priest, considering it only as proof of solemnization and not an authentic document to prove filiation or marital status.

ISSUE

Whether the Workmen’s Compensation Commission erred in denying the claim for death benefits on the ground of insufficient proof of marriage between the claimant and the deceased employee.

RULING

Yes. The Supreme Court reversed the Commission’s decision. The legal logic is anchored on the application of disputable presumptions, the nature of workmen’s compensation proceedings, and the policy of the law as social legislation.
The Court held that the Commission disregarded the presumption under Section 5(bb), Rule 131 of the Rules of Court, which states that a man and a woman deporting themselves as husband and wife are presumed to have entered into a lawful contract of marriage. The deceased and petitioner had lived together as husband and wife for many years and had several children who were all of legal age. This presumption, satisfactory if uncontradicted, stood in petitioner’s favor. Furthermore, the parish priest’s certificate of marriage was indeed competent evidence to prove the fact of marriage, as supported by jurisprudence. Petitioner also later submitted a certificate of registration from the Civil Register.
Critically, the respondent Republic presented no evidence to rebut the claimant’s status as the widow. The Office of the Solicitor General even recommended affirmance of the award. The Court emphasized that workmen’s compensation proceedings are not governed by technical rules of evidence; substantial evidence suffices. The Workmen’s Compensation Act is social legislation intended to benefit laborers and their dependents. In case of doubt, resolutions should be in their favor. This policy is especially compelling here, where the claimant, left without support, litigated as a pauper. The award was thus reinstated and modified.