Floresca v. Philex Mining Corp. (G.R. No. L-30642)

Facts:

• A mining accident occurred on June 28, 1967, at Philex Mining Corporation's copper mines in Tuba, Benguet.
• The accident led to the deaths of several employees.
• The heirs of the deceased, including Perfecto S. Floresca, filed a complaint for damages against Philex Mining Corporation.
• The heirs claimed Philex negligently and deliberately failed to implement necessary safety measures, causing a cave-in and fatalities.
• They sought actual, moral, and exemplary damages totaling P825,000.00.
• Philex filed a motion to dismiss, arguing the claims were exclusively covered by the Workmen's Compensation Act, which provides specific remedies for work-related injuries and deaths.
• The lower court agreed with Philex and dismissed the case, stating it fell under the exclusive jurisdiction of the Workmen's Compensation Commission.
• The petitioners appealed, arguing their claim was based on the Civil Code provisions on damages due to gross negligence, not on the Workmen's Compensation Act.

Issue:

• (Unlock)

Ruling:

1. The Supreme Court ruled that the heirs of the deceased employees could pursue their claim for damages under the Civil Code, even if they had received compensation under the Workmen's Compensation Act.
2. The Court rever...(Unlock)

Ratio:

• The Supreme Court clarified that the petitioners' complaint was not for compensation under the Workmen's Compensation Act but for damages based on gross and reckless negligence under the Civil Code.
• The Workmen's Compensation Act and the Civil Code serve different purposes: the former provides compensation for work-related injuries regardless of fault, while the latter allows for damages as a remedy for wrongful invasion of rights due to negligence.
• Receiving compen...continue reading