Belandres vs. Lopez Sugar Central Mill Co., Inc.

G.R. No. L-6869
A train conductor’s death led to a claim for negligence damages, contested as a workers’ compensation case; court ruled for jurisdictional merit.

Case Digest (G.R. No. L-6869)

Facts:

Soledad Belandres v. Lopez Sugar Central Mill Co., Inc., G.R. No. L-6869, May 27, 1955, the Supreme Court En Banc, Labrador, J., writing for the Court. Pablo, Acting C.J., Bengzon, Montemayor, Reyes, A., Bautista Angelo, Concepcion, and Reyes, J. B. L., JJ., concur.

Plaintiff-appellant Soledad Belandres sued defendant-appellee Lopez Sugar Central Mill Co., Inc. for P9,000 as damages for the death of her son, Querubin Villa, who was employed by defendant as a train conductor engaged in transporting cane to the mill. The complaint alleged that on May 5, 1952 Villa was riding as train conductor on an empty car when a number of empty cars were derailed due to the negligence of defendant’s employees (engine driver, superintendent, brakemen and inspector); Villa supposedly fell and was run over by the following cars, suffering fatal injuries.

Defendant admitted that Villa was employed by it and died in a derailment, but denied that the cars were under its direct control or that the derailment was caused by its employees’ negligence. The defendant alleged that it was Villa’s duty as conductor or brakeman to see that the track was clear and to notify the machinist of any obstruction and that Villa, with negligence, failed to discover pieces of iron placed on the rails by a third party and failed to give the signal to stop the train. After pleadings were joined the parties entered into a partial stipulation of facts, the principal point being that death resulted from a derailment caused by an obstacle on the rails.

Plaintiff presented evidence to support negligence. When plaintiff rested, counsel for defendant moved to dismiss for want of jurisdiction on the ground that the claim was in substance one for workmen’s compensation governed by the Workmen’s Compensation Act (Act No. 3428, as amended by subsequent enactments), and therefore outside the court’s jurisdiction. The trial court granted the motion and dismissed the complaint, explaining that the claim was a compensation claim under the special law (citing Act No. 3428 and Article 2196 of the Civil Code) and thus not cognizable in the court.

Belandres appealed the ...(Pro-only)

Issues:

  • Did the trial court err in dismissing the action for lack of jurisdiction on the ground that the claim was a workmen’s compensation case?
  • Was the complaint, as pleaded, a claim for compensation under the Workmen’s Compensation Act rather than an action in tort for damages under Articles 2176 and 2180 of the Civil Code?
  • Can an attorney’s alleged admission bind the client as to the subject matter or cause of action so as to d...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)

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