Case Digest (CA-No. 773, 774, 775)
Facts:
- The case "Abueg v. San Diego" involves three consolidated appeals (CA-No. 773, 774, 775) from judgments rendered by the Court of First Instance of Manila.
- Plaintiffs-appellees: Dionisia Abueg, Marciana de Salvacion, and Rosario Oching, widows of Amado Nuez, Victoriano Salvacion, and Francisco Oching, respectively.
- The deceased were employees on board the motor ships San Diego II and Bartolome S, owned by defendant-appellant Bartolome San Diego.
- On October 1, 1941, the ships were caught in a typhoon near Mindoro Island and sank, resulting in the deaths of the employees.
- The lower court awarded compensation to the plaintiffs under the Workmen's Compensation Act.
- The appellant argued that his liability was extinguished due to the total loss of the vessels, citing provisions from the Code of Commerce.
- The case was forwarded to the Supreme Court after the records were reconstituted post-World War II destruction.
Issue:
- (Unlock)
Ruling:
- No, the liability of the shipowner was not extinguished.
- No, the provisions of the Code of Commerce are not applicable in the context of the Workmen's Compensation Act.
- Yes, the deceased empl...(Unlock)
Ratio:
- The Supreme Court ruled that the real and hypothecary nature of the liability of the shipowner or agent, as embodied in the provisions of the Maritime Law and the Code of Commerce, originated from the medieval conditions of maritime trade, which were fraught with hazards and perils.
- These provisions were designed to encourage shipbuilding and maritime commerce by limiting the shipowner's liability to the vessel, equipment, and freight.
- However, the Workmen's Compensation Act seeks to improve the conditions of laborers and employees by creating a liability to compensate them or their heirs in cases of injury or death caused by their employment.
- This liability is distinct from the provisions of the Code of Commerce and is considered an item in the costs of production that must be included in the budget of any well-managed industry.
- The court further clarified that the Workmen's Compensation Act was enacted to abrogate common law and civi...continue reading
Case Digest (CA-No. 773, 774, 775)
Facts:
The case "Abueg v. San Diego" involves three consolidated appeals (CA-No. 773, 774, 775) from judgments rendered by the Court of First Instance of Manila. The plaintiffs-appellees, Dionisia Abueg, Marciana de Salvacion, and Rosario Oching, are the widows of Amado Nuez, Victoriano Salvacion, and Francisco Oching, respectively. These individuals were employees on board the motor ships San Diego II and Bartolome S, both owned by the defendant-appellant, Bartolome San Diego. On October 1, 1941, while engaged in fishing operations around Mindoro Island, the ships were caught in a typhoon and subsequently sunk, resulting in the deaths of the employees. The lower court awarded compensation to the plaintiffs under the Workmen's Compensation Act. The appellant argued that his liability was extinguished due to the total loss of the vessels, citing provisions from the Code of Commerce. The case was forwarded to the Supreme Court after the records were reconstituted post-World War II destruction.
Issue:
- Was the liability of the shipowner extinguished under the Code of Commerce due to the total loss of the vessels?
- Are the provisions of the Code of Commerce applicable in the context of the Workmen's Compensation Act?
- Were the deceased employees considered industrial employees under the Workmen's Compensation ...