Facts:

The case involves Lucia Europa, the mother of the deceased Lucrecia Europa, as the petitioner against Hunter Garments Manufacturing (Phil.) Inc. and the Intermediate Appellate Court as respondents. The events leading to the case began in 1973 when Lucrecia was employed as a sample maker by Hunter Garments. On March 9, 1978, Lucrecia suffered a fatal electrocution while operating a high-speed sewing machine assigned to her by the company. Following this tragic incident, Lucia Europa filed a complaint for damages against Hunter Garments on July 18, 1980, based on quasi-delict. The summons and a copy of the complaint were served to the production manager, Mr. Simplicio A. Garcia, but the company failed to file an answer. Consequently, the trial court declared the private respondent in default, allowing the petitioner to present evidence ex parte. On April 8, 1981, the trial court rendered a judgment in favor of the petitioner, awarding damages totaling P62,580.00, which included...

Facts:

Employment and Incident

• In 1973, Lucrecia Europa was employed as a sample maker by Hunter Garments Manufacturing (Philippines) Incorporated.
• On March 9, 1978, Lucrecia was electrocuted by a high-speed sewing machine assigned to her by the company.

Legal Action

• On July 18, 1980, Lucia Europa (Lucrecia’s mother) filed a damages suit against Hunter Garments based on quasi-delict.
• Summons and a copy of the complaint were served on Simplicio A. Garcia, the company’s production manager.
• No answer was filed by the respondent, leading to a declaration of default and an ex parte presentation of evidence by the petitioner.

Trial Court Decision

• On April 8, 1981, the trial court ruled in favor of Lucia Europa, awarding:
  • P12,000.00 for Lucrecia’s death,
  • P5,580.00 for funeral and burial expenses,
  • P30,000.00 for loss of income,
  • P10,000.00 for moral damages,
  • P5,000.00 for attorney’s fees, and
  • Costs of the suit.

Respondent’s Motion and Appeal

• Hunter Garments filed a motion for reconsideration and a motion to admit an answer, citing excusable negligence by its secretary, Lilia Jimenez, who failed to forward the summons to the company president.
• The trial court denied both motions.
• Hunter Garments appealed to the Court of Appeals, arguing:
  1. Failure to file an answer was due to excusable negligence.
  2. Summons was improperly served.
  3. The trial court’s decision was unsupported by law and facts.

Court of Appeals Decision

• The Court of Appeals ruled that the trial court did not acquire jurisdiction over Hunter Garments due to improper service of summons (the production manager was not the proper "manager" under Rule 14, Section 13 of the Revised Rules of Court).
• The default order and judgment were set aside, and the case was remanded for further proceedings.

Petition for Certiorari

• Lucia Europa filed a motion for reconsideration, which was denied, prompting her to file a petition for certiorari with the Supreme Court.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Jurisdiction by Submission:

   • Even if the trial court initially lacked jurisdiction due to improper service of summons, Hunter Garments submitted to the court’s jurisdiction by filing a motion for reconsideration and a motion to admit an answer. (Citing Soriano v. Palacio, 12 SCRA 449.)

2. Excusable Negligence:

   • The Court found no merit in the claim of excusable negligence, as the respondent’s failure to file an answer was due to internal mismanagement, not an excusable oversight.

3. Liability for Quasi-Delict:

   • The evidence established gross negligence on the part of Hunter Garments, including:
     • Failure to address prior incidents of machine grounding.
     • Lack of a licensed electrical engineer and inadequate maintenance.
     • Apathy toward employee safety.
   • Under Article 2202 of the New Civil Code, all damages for the natural and probable consequences of the act or omission are recoverable in quasi-delict cases.

4. Damages Awarded:

   • The damages awarded by the trial court were reasonable and supported by evidence, except for the indemnity for death, which was increased to P30,000.00 to align with prevailing jurisprudence.