G.R. No. L-36244 November 29, 1974
ABAYA PLUMBING, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and CRESENCIANA VDA. DE DATINGINOO, respondents.

FACTS

Santiago Datinginoo, husband of private respondent Cresenciana Vda. de Datinginoo, died on July 1, 1967, after falling from a floor of the Philippine National Bank building under construction at Escolta. He sustained a fractured skull while connecting a pipe and died shortly after arrival at the Philippine General Hospital. Petitioner Abaya Plumbing, the plumbing sub-contractor at the site, was impleaded as the employer. The Workmen’s Compensation Commission reversed its Referee’s order and awarded death benefits, burial expenses, attorney’s fees, and costs to the widow.
The core factual dispute was the existence of an employer-employee relationship. The Commission found that Datinginoo began working at the site on June 24, 1967, hired as a helper by Jose Maravillosa, who represented himself as a foreman for Abaya Plumbing. Datinginoo worked continuously until his fatal accident. Supporting evidence included Maravillosa’s affidavit confirming his foreman role and the hiring, the uninterrupted seven-day work period, and the widow’s receipt of P42.00 for her husband’s wages and P50.00 as burial assistance from Abaya Plumbing.

ISSUE

Whether an employer-employee relationship existed between Abaya Plumbing and the deceased Santiago Datinginoo at the time of the fatal accident.

RULING

The Supreme Court affirmed the Commission’s decision, ruling that an employer-employee relationship was established. Petitioner’s defense, denying employment and Maravillosa’s authority to hire, relied on testimonies from owner Cesar Abaya, Maravillosa (who recanted his affidavit), and foreman Magno Celestino, plus the absence of Datinginoo’s name in social security and payroll records. The Court found this verbal evidence insufficient to overcome the claimant’s proof.
The legal logic centered on the weight accorded to substantive evidence of employment over formal record-keeping deficiencies. Maravillosa’s affidavit, though later recanted, was a prior solemn statement whose credibility the Commission rightly upheld. The fact of continuous work for seven days without intervention from management strongly implied knowledge and acquiescence, constituting implied hiring. The payment of wages and burial assistance by the company directly to the widow was a concrete act acknowledging a compensatory obligation arising from employment. The absence of the deceased’s name in social security or payroll records was not decisive, as such formal inclusion is a subsequent administrative act for a newly hired employee and does not negate the substantive relationship created by the performance of work and payment. The Workmen’s Compensation Act is a social legislation, and doubts are resolved in favor of the employee’s beneficiaries. Thus, the Commission’s award was sustained.