G.R. No. L-49084 October 10, 1985
MATILDE ALAVADO, in her own right and as natural guardian of IDA VILMA, IMELDA AND ROLANDO, all surnamed ALAVADO, petitioner, vs. CITY GOVERNMENT OF TACLOBAN (ENGINEER’S OFFICE AND WORKMEN’S COMPENSATION COMMISSION, now the LABOR APPEALS AND REVIEW STAFF), respondents.

FACTS

Ricardo Alavado, a carpenter-foreman employed by the City Engineer’s Office of Tacloban City, died on August 7, 1974, of a cerebral hemorrhage suffered while supervising a construction project. His surviving spouse, Matilde Alavado, filed a claim for death benefits under the Workmen’s Compensation Act on behalf of herself and their minor children. The Hearing Officer granted the claim, awarding P5,200.00 in death benefits and P200.00 for burial expenses.
The City Government appealed to the Workmen’s Compensation Commission. The Commission, while admitting the compensability of the death, dismissed the claim. It held that Matilde failed to sufficiently prove her marital status and the filiation of the children. The Commission ruled that the marriage certificate she initially presented, issued by a parish church, was not authentic proof. It required either the original marriage contract, a certificate from the local civil registrar, or, in their absence, secondary evidence like affidavits from the claimant and three witnesses. For the children, it deemed the presented baptismal certificates insufficient to establish filiation.

ISSUE

The primary issue is whether the petitioner sufficiently proved her marriage to the deceased and the dependency of their children to be entitled to death benefits under the Workmen’s Compensation Act.

RULING

The Supreme Court granted the petition, reversed the Commission’s decision, and reinstated the Hearing Officer’s award. The Court held that the Commission committed a grave error in dismissing the claim based on an overly strict and technical assessment of the evidence regarding marital status.
On the proof of marriage, the Court applied the legal presumption under Section 5(bb), Rule 131 of the Rules of Court: “That a man and a woman deporting themselves as husband and wife have entered into a lawful contract of marriage.” The petitioner and the deceased had lived together as husband and wife continuously for 35 years until his death, a fact not denied by the respondent. This presumption, founded on public policy favoring the legality of marriage, is strong and can only be rebutted by cogent evidence. The respondent city presented no evidence to contradict it. Furthermore, the petitioner later submitted a certified copy of the marriage contract from the local civil registrar, which definitively established the marriage between Ricardo Alavado and Matilde Valdesco (the petitioner) solemnized in 1939. This document conclusively resolved the issue.
Regarding the respondent city’s belated defense that Alavado was no longer its employee at the time of death, the Court ruled it was barred. Under the Workmen’s Compensation Act, the employer must controvert the claim within 14 days from death or 10 days from knowledge. The city’s failure to do so within this reglementary period constituted a waiver of its right to challenge compensability. The Act, as a social legislation, must be interpreted liberally in favor of laborers to fulfill the constitutional mandate of social justice. The Commission’s dismissal, based on a technicality despite the clear presumption of marriage and the city’s failure to timely controvert, was a reversible error.