G.R. No. 46135 - Copiaco vs. Luzon Brokerage Co., Inc.

The case involved Pedro Morales, accused in criminal case No. 49898 before the Court of First Instance of Manila for quadruple homicide through reckless imprudence.
Morales, acting as the chauffeur and person in charge of truck No. T-1179, allegedly drove recklessly along Rizal Avenue Extension on or about April 24, 1935, causing the truck to hit a carretela.
The impact resulted in four passengers—Fidel Copiaco, Delfin Copiaco, Leonardo Reyes, and Juan Reyes—being thrown to the ground, sustaining injuries that directly caused their deaths.
The amended information described the accused’s actions as willful, unlawful, and lacking the necessary precautions to avoid the accident.

Despite the charge being one of multiple homicide through reckless imprudence, Morales was found guilty only of a violation of section 67(d) of the Revised Motor Vehicle Law (Act No. 3992).
The court imposed an indeterminate penalty ranging from three to six years of imprisonment.
Additionally, Morales was ordered to indemnify the family of each deceased with the sum of P500 and to pay the trial costs.
With no appeal, the judgment became final and was executed; however, Morales’ insolvency prevented the payment of the awarded indemnities.

The heirs of the deceased initiated separate civil cases against Luzon Brokerage Co., Inc., arguing that the company was responsible as the employer of Morales and owner of the truck involved.
Alfredo Copiaco and Nieves Alarcon, as the legitimate parents and sole heirs of Fidel Copiaco, filed an action for P500 indemnity with legal interest and costs.
A similar action was filed by the Copiaco spouses, who are also the legitimate parents of Delfin Copiaco. They additionally sought an extra indemnity of P8,000 for damages related to the deaths of both their children.
The spouses Jesus Reyes and Victoria Reyes, as the sole legitimate heirs of Leonardo Reyes, brought an action for P500 with legal interest and costs.
Benita Pelagio, Juliana Reyes, Victoria Reyes, Flora Reyes, and Asuncion Reyes, the widow and children of Juan Reyes, likewise instituted a suit for P500 with legal interest and costs.
These four civil actions were later consolidated and tried jointly in the Court of First Instance of Manila, which rendered a judgment requiring Luzon Brokerage Co., Inc. to pay each plaintiff the indemnity of P500 with legal interest and costs.

Luzon Brokerage Co., Inc. appealed from the joint judgment.
The central question revolved around whether the company, as the employer of Morales and owner of the truck, was civilly and subsidiarily liable for the indemnity awarded in the criminal case following Morales’ insolvency.
The court’s decision relied on the principles set forth in articles 10 and 103 of the Revised Penal Code, which promote the supplementary application of the Penal Code to offenses under special laws, such as the Revised Motor Vehicle Law.

Whether Luzon Brokerage Co., Inc. can be held civilly and subsidiarily liable for the indemnities awarded against Pedro Morales in the criminal case, given that he was insolvent.

Does the principle of subsidiary liability extend to a corporation that employs an employee who commits a reckless act causing fatal injuries?
Can the indemnities, though not expressly provided for under the Revised Motor Vehicle Law, be recovered under the supplementary provisions of the Revised Penal Code?

Whether the Revised Motor Vehicle Law (Act No. 3992) qualifies as a special law under article 10 of the Revised Penal Code.

Is the application of article 103, which imposes subsidiary civil liability on employers for offenses committed by their employees, valid in this instance?
How does the established jurisprudence, notably People vs. Moreno, influence this determination?

Whether the amount of indemnity awarded (P500 for each victim) is appropriate, particularly in view of the argument that some families were doubly affected due to multiple deaths within one family.

Should the indemnification for the families of Delfin Copiaco and Fidel Copiaco, being from the same family, be computed differently, or is it justifiable to award P500 per victim?