Case Digest (G.R. No. 59621)
Facts:
The case involves Maximiliano Alvarez as the petitioner against the Hon. Court of Appeals, Hon. Milagros V. Caguioa (Presiding Judge of Branch VIII, Court of First Instance of Quezon and Lucena City), Atty. Eleno M. Joyas (Provincial Sheriff of Quezon), Francisco T. Fortunado (Deputy Sheriff of Quezon), and Atty. Felicisimo S. Garin as respondents. The events leading to this case began when Renato Ramos was charged with Double Homicide with Multiple Serious Physical Injuries Through Reckless Imprudence in the Court of First Instance of Quezon Province. After a trial, the court found Ramos guilty of negligence and imposed a fine of P200.00, along with civil liabilities for the deaths and injuries resulting from a vehicular collision. The court ordered Ramos to indemnify the heirs of the deceased and the injured parties with specified amounts totaling P60,000.00. The trial court also held Alvarez, as Ramos's employer, subsidiarily liable for these indemnities, stating that ...
Case Digest (G.R. No. 59621)
Facts:
- Petitioner: Maximiliano Alvarez, engaged in the business of buying coconuts and copra for resale, who was implicated as an employer.
- Respondents:
Parties and Background
- Renato Ramos was tried and found guilty of negligence in connection with a collision that resulted in the deaths of Rodolfo and Juan Briones as well as injuries to other parties.
- The trial court’s judgment:
Trial Court Proceedings and Judgment
- In CA-G.R. No. 19077-CR, the Court of Appeals affirmed the trial court’s decision regarding Ramos’ conviction but deleted the portion holding Alvarez subsidiarily liable.
- The appellate decision reasoned that:
Appellate Court (Court of Appeals) Actions
- The petition was docketed as CA-G.R. No. SP-10069.
- On 16 May 1980, the Court of Appeals granted the petition, nullifying the subsidiary writ of execution, referring to its earlier judgment in CA-G.R. No. 19077-CR and the later Supreme Court decision in Pajarito v. Seneris (which held that a separate action must be filed to enforce an employer’s subsidiary liability).
- Respondents later filed a Motion for Reconsideration which, on 23 October 1980, led the appellate court to set aside its earlier decision and reinstate the subsidiary liability based on the Pajarito ruling.
- Petitioner Alvarez then filed a petition for certiorari before the Supreme Court, contending that:
Developments on Reconsideration and Supreme Court Pronouncements
- The Supreme Court denied Alvarez’s petition for review.
- It affirmed the resolutions of the Court of Appeals dated 23 October 1980 and 20 January 1982.
- The decision emphasized that:
Final Outcome in the Supreme Court
Issue:
- The question revolves around due process rights given that the employer was not afforded the opportunity to contest his alleged subsidiary liability at the criminal trial.
Whether it is proper, for purposes of enforcing subsidiary civil liability, to include an employer (who is not an original party) in the criminal proceeding of an employee’s conviction.
- Consideration was given to the fact that the provisions of Articles 102 and 103 of the Revised Penal Code are deemed operative upon the employee’s conviction regardless of their inclusion in the trial court’s order.
Whether the trial court’s explicit pronouncement of the employer’s subsidiary liability was appropriate or was merely a superfluous statement.
- Determining if the doctrine should preclude or allow reconsideration of a prior appellate decision based solely on technical grounds without affecting the merits.
The applicability and limits of the “law of the case” doctrine in this context.
- Assessing if such delays amount to a violation of due process that would require a separate suit against the employer.
Whether any procedural irregularities—such as the delayed service of the appellate decision on respondents’ counsel—could merit reversing the enforcement of subsidiary liability.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)