GR 50180; (December, 1981) (Digest)
G.R. No. L-50180 December 19, 1981
FRANCISCA RICO REYES, for herself and on behalf of her minor children, FERNANDO, REBECCA and IAN, all surnamed Reyes, petitioners, vs. THE OFFICE OF THE MINISTER OF LABOR and RIZAL CEMENT COMPANY, INC., respondents.
FACTS
Petitioner Francisca Rico Reyes, the common-law wife of the late Edilberto P. Reyes, filed a claim for death benefits after Edilberto died in a work-related accident on January 8, 1969, while employed as Assistant Chief Security Officer of Rizal Cement Company, Inc. Surviving him were Francisca and their three minor children. The Acting Referee of the Department of Labor ruled the death was compensable but denied the award, holding that the petitioner and her children were not the legal dependents of the deceased. This decision was affirmed by the Workmen’s Compensation Commission.
The procedural history became complex due to the phasing out of the Workmen’s Compensation Commission. The petitioner alleged she did not receive a copy of the Commission’s adverse decision promptly due to the administrative transition and loss of contact with her counsel. Upon learning of the decision, she filed a motion for reconsideration with the Department of Labor, which was denied for being filed out of time and with the wrong forum, as the proper appeal was directly to the Supreme Court. The petitioner subsequently sent a letter-appeal to the Office of the President, which referred it back to the Secretary of Labor.
ISSUE
The principal issues were: (1) whether the appeal to the Office of the President, instead of the Supreme Court, rendered the Commission’s decision final and executory; (2) whether the appeal to the Supreme Court was seasonably made; and (3) whether the three minor children could be considered legal dependents entitled to death benefits.
RULING
The Supreme Court granted the petition. On the procedural issues, the Court held that the confusion following the abolition of the Workmen’s Compensation Commission justified the delay. There was no proof that the petitioner’s counsel received the Commission’s decision. Consequently, the decision had not become final when the motion for reconsideration was filed. Citing Obor vs. Workmen’s Compensation Commission, the Court ruled that filing an appeal in the wrong forum does not defeat the claim; the appeal to the President constituted substantial compliance with the requirement to appeal within ten days.
On the substantive issue, the Court held the three children were legal dependents entitled to benefits. The deceased had acknowledged Fernando and Rebecca as his children in a Sworn Statement of Financial Condition, which constituted a sufficient authentic acknowledgment under Article 278 of the Civil Code. This recognition redounded to the benefit of their brother, Ian, pursuant to Article 271. Therefore, all three children were legal dependents. The Court set aside the Commission’s decision and ordered Rizal Cement Company to pay P6,000.00 as death compensation, P600.00 as attorney’s fees, and P61.00 as an administrative fee.