Case Digest (G.R. No. L-30642) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Perfecto S. Floresca, et al. vs. Philex Mining Corporation (G.R. No. L-30642, April 30, 1985, 220 Phil. 533), the petitioners are the heirs of five miners who perished in a cave-in at Philex’s Tuba, Benguet copper mine on June 28, 1967. Their complaint filed before Branch XIII of the Court of First Instance of Manila sought actual, moral and exemplary damages totaling ₱825,000 under Civil Code Articles 2176, 2178, 1173, 2201 and 2231, alleging that Philex’s “gross and reckless negligence” and deliberate failure to take government-mandated precautions caused the collapse. Philex moved to dismiss for lack of jurisdiction, asserting exclusivity of the Workmen’s Compensation Act (Act No. 3428, as amended by R.A. 772). The trial court initially dismissed the complaint (June 27, 1968), then reinstated it (September 23, 1968), and finally again dismissed it (December 16, 1968). The Supreme Court was asked to review whether the CFI had jurisdiction and whether Civil Code tort claims Case Digest (G.R. No. L-30642) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Lower Proceedings
- Petitioners: Heirs of 21 miners (including Floresca, Martinez, Obra, Villar, Lanuza, Isla) who died in an underground cave-in at Philex Mining Corporation’s Tuba, Benguet copper mine on June 28, 1967.
- Respondents: Philex Mining Corporation and Judge Jesus P. Morfe of CFI, Branch XIII, Manila.
- Complaint: Filed in CFI for actual, moral and exemplary damages of ₱825,000 under Civil Code Articles 2176, 2178, 1173, 2201 and 2231, alleging gross and reckless negligence by Philex in failing to install safety measures, leading to collapse, flooding and entombment of miners.
- Procedural History
- May 14, 1968: Philex moves to dismiss for lack of jurisdiction, invoking exclusivity of Workmen’s Compensation Act (WCA).
- May 27, 1968: Petitioners oppose, stressing their cause of action is in tort under the Civil Code, not WCA.
- June 27, 1968: CFI dismisses case for exclusive jurisdiction of Workmen’s Compensation Commission.
- Sept. 23, 1968: On motion for reconsideration, Judge Morfe sets aside dismissal and allows answer.
- Dec. 16, 1968: Judge Morfe again dismisses for lack of jurisdiction, ruling WCA remedies exclusive.
- Petitioners elevate case to Supreme Court.
Issues:
- Jurisdictional Scope
- Whether the CFI has jurisdiction over the complaint for damages under the Civil Code as distinct from a compensation claim under the WCA.
- Whether the lower court erred in applying the exclusivity clause of the WCA to bar Civil Code claims.
- Remedy Selection
- Whether heirs may choose between WCA compensation and Civil Code damages, or must accept WCA remedy exclusively.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)