GR L 19946; (February, 1965) (Digest)
G.R. No. L-19946 February 26, 1965
REPUBLIC OF THE PHILIPPINES, petitioner, vs. THE WORKMEN’S COMPENSATION COMMISSION and IRENE FERNANDEZ VDA. DE ESPIRITU, for herself and in behalf of the minors MANUEL and JOSE, both surnamed ESPIRITU, respondents.
FACTS
Gregorio H. Espiritu died of pulmonary tuberculosis contracted while working as a letter-carrier in the post office of Libmanan, Camarines Sur. The Workmen’s Compensation Commission granted compensation benefits to his widow, Irene Fernandez, and to two minors, Manuel and Jose Espiritu, who were alleged to be the illegitimate (spurious) children of the deceased by another woman. The Republic of the Philippines filed a petition for review, not disputing the compensability of the death nor the award to the widow, but objecting to the extension of death benefits to the two minors.
ISSUE
Whether the two minor children, alleged to be illegitimate (spurious) children of the deceased, are entitled to compensation benefits under the Workmen’s Compensation Law.
RULING
The Supreme Court modified the decision of the Workmen’s Compensation Commission. The award of compensation to the two minors, Manuel and Jose Espiritu, was eliminated. The Court held that while it was unnecessary to resolve the issue of whether spurious children could be considered dependents under the Workmen’s Compensation Law, the claim on behalf of the minors must fail because their filiation to the deceased had not been established. The only evidence presented were their baptismal certificates, which are not considered records of birth or authentic writing sufficient to prove voluntary recognition under the Civil Code. The fact that the minors lived with and were supported by the deceased could be a ground for compulsory recognition, but no suit for that purpose had been instituted, a matter within the jurisdiction of the courts and not the Workmen’s Compensation Commission. The widow, Irene Fernandez Vda. de Espiritu, was entitled to receive the full compensation amount of P2,741.44, representing 45% of the deceased’s weekly salary for 208 weeks. The decision was affirmed in all other respects.