Facts:

This case revolves around A.D. Santos, Inc. (petitioner) and Carolina Gomintong (respondent), along with the Workmen's Compensation Commission (WCC). The incident in question occurred on November 12, 1970, when Ruben Gomintong, the deceased husband of the respondent, was fatally shot during a robbery while driving a taxi owned by the petitioner. The respondent filed a claim for death compensation benefits, which the petitioner did not dispute, acknowledging the claim’s compensability. However, the core of the petitioner's argument is based on their contention that they had previously paid the respondent a total of P6,800 on November 17, 1970, which included P6,000 for death benefits and P800 for medical and caretaking expenses. This payment was evidenced by a bank check, a voucher, and a quitclaim signed by the respondent and the deceased's parents.

The petitioner first learned of the claim against them from the WCC’s regional office on December 21, 1970, to which t

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Facts:

Background of the Case

• A.D. Santos, Inc. (petitioner) was involved in a dispute regarding the claim for death compensation filed by respondent-claimant Carolina Gomintong, the widow of its driver-employee, Ruben Gomintong.
• The driver was fatally shot by robbers on November 12, 1970 while driving a City Cab taxi operated by petitioner.

Payment and Documentary Evidence

• Petitioner voluntarily paid a total sum of P6,800.00 on November 17, 1970, which was composed of P6,000 for death benefit and P800 for ancillary expenses (medicine, hospital, doctors, and caretaker bills).
• The payment was supported by three key documents:
• An encashed Bank of the Philippine Islands check (No. C-282649) for P6,800.00, bearing the respondent’s signature on the back.
• A company voucher signed by the respondent, evidencing receipt of the said check.
• A Deed of Quitclaim and Release, duly executed and notarized, signed by the respondent and the deceased’s parents (Jose Gomintong and Benigna Gaqueng).

Proceedings and Alleged Procedural Irregularities

• The Workmen's Compensation Commission received notice of the claim on December 21, 1970 from its regional office.
• Petitioner promptly replied that the full claim had been settled.
• A hearing notice was then issued on June 14, 1971 for a proceeding scheduled in Naga City on June 18, 1971, despite a change in venue that seemingly violated procedural rules regarding adverse party consent.
• Petitioner, in response to the short notice, sent a telegram and a motion to postpone the hearing until its motion to dismiss (based on prior payment) could be resolved.
• The hearing officer denied the postponement request and conducted the hearing on June 18, 1971, obtaining ex parte evidence from the respondent-claimant.

Submission of Motion and Evidence

• On June 22, 1971, petitioner filed a motion to dismiss the claim on the basis that the debt had already been settled, submitting the documentary evidence of payment with the motion.
• On June 23, 1971, notwithstanding the pending motion to dismiss, the hearing officer rendered an award against petitioner.
• Petitioner then filed a motion for reconsideration on the award during a hearing on August 6, 1971, where petitioner’s representative Marcelo Dilao testified.

Contested Evidence and Claimant’s Denials

• At the hearing for reconsideration, respondent-claimant admitted to having signed the documentary evidences but claimed the signatures were “in blank” or not deliberately executed.
• Her explanations regarding the encashed check and absence from the bank further cast doubts, though her denials remained uncorroborated.

Commission’s Findings and Subsequent Developments

• The Workmen's Compensation Commission, both in its initial decision and in an en banc resolution of August 28, 1972, expressed skepticism about the authenticity of the evidence of payment.
• The Commission based its conclusion partially on respondent-claimant’s assertion of having signed the documents in blank and hinted at possible fraud without presenting corroborative evidence.
• The petitioner argued that these findings deprived it of a fair opportunity to prove its defense of previous payment, as the documents in question held inherent evidentiary value.

Issue:

Whether the petitioner was deprived of its right to a fair hearing by being denied a proper opportunity to present and corroborate its defense of full payment.

• The procedural irregularities, such as the change of venue and the denial of a postponement, are central to this issue.
• The impact on the petitioner’s ability to effectively contest respondent-claimant’s assertions is critically examined.

Whether the documentary evidence presented by the petitioner (encashed check, company voucher, and notarized quitclaim) sufficiently establishes its defense of prior full payment.

• This includes assessing the weight and credibility of these documents despite respondent-claimant’s claims that they were executed in blank.
• Whether the presumed integrity of public or notarized documents should override uncorroborated denials and allegations of forgery.

• Whether the Workmen's Compensation Commission erred in relying on respondent-claimant’s uncorroborated disclaimers to uphold its award against the petitioner.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)