Title
Cuevo vs. Barredo
Case
G.R. No. 45699
Decision Date
Feb 24, 1938
Employer liable for worker’s drowning after foreman’s negligent order to retrieve log, reversed by Supreme Court under Employer’s Liability Act.

Case Digest (G.R. No. 45699)
Expanded Legal Reasoning Model

Facts:

On August 3, 1935, during a typhoon in Manila when the Pasig River was swift and strong, Anastacio Lozano was employed as a carpenter by defendant Fausto Barredo. He was involved in constructing a concrete pier and bridge annex. A log, not secured and intended to be used as a pile in the construction, was carried away by the current after being disturbed by a wave generated by a passing launch. Yoshio Tagashira, the defendant’s foreman, observed the log being carried off and, with a threatening tone that implied the laborers would be held responsible for its loss, ordered its immediate recovery. Relying on his ability as a good swimmer and the urgency imposed by his superior’s command, Lozano leaped into the river to recover the log but was tragically drowned. Evidence showed that Lozano’s actions stemmed from the immediate pressure of the foreman’s order and the fear of personal financial liability, rather than a calculated decision to risk his life.

Issues:

  • Whether the defendant, as employer, is liable for the death of Anastacio Lozano under section 1, clause 1 and clause 2 of Act No. 1874, as amended by Act No. 2473.
  • Whether the negligence of the foreman in issuing the hazardous command, without taking precautions to protect the employee, constitutes sufficient grounds to impose liability on the employer through the principle of vicarious liability.
  • Whether the laborer’s action of leaping into the river, given his known ability to swim and under the immediate influence of the foreman’s order, can be attributed to his own negligence or should be excused on the basis that he lacked time to fully appreciate the risk involved.
  • Whether the complainant’s allegations, which did not explicitly state the foreman’s negligence, are sufficient to establish a cause of action under the stipulated law.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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