Case Digest (G.R. No. L-8110)
Facts:
On August 23, 1951, Pedro Mamador and other laborers of MARINDUQUE IRON MINES AGENTS, INC. boarded a company truck in Bo. Sumangga, Mogpog, Marinduque; the truck, driven by Procopio Macunat, overturned en route to Talantunan, causing Mamador's death. Macunat was criminally prosecuted in Criminal Case No. 1491, convicted and ordered to indemnify the heirs, but paid nothing; the Referee awarded compensation to the HEIRS OF PEDRO MAMADOR, which the WORKMEN'S COMPENSATION COMMISSION confirmed, and petitioner sought certiorari contesting only the right to compensation.Issues:
- Was petitioner denied the opportunity to cross-examine adverse witnesses in violation of procedural due process?
- Did Section 6 of the Workmen's Compensation Law bar the claim because of the criminal conviction and an alleged amicable settlement with the third party?
- Did Mamador's violation of the employer's prohibition against riding haulage trucks constitute notorious negligence precluding recovery?
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Case Digest (G.R. No. L-8110)
Facts:
- Parties and capacity
- MARINDUQUE IRON MINES AGENTS, INC. — Petitioner employer.
- THE WORKMEN'S COMPENSATION COMMISSION, THE HEIRS OF PEDRO MAMADOR, and GERONIMO MA. COLL — Respondents.
- Accident circumstances
- Date and place — August 23, 1951, at 6:00 a.m., Bo. Sumangga, Mogpog, Marinduque.
- Events — Deceased Pedro Mamador and other laborers boarded a company truck driven by Procopio Macunat, on the way to the mine camp at Talantunan; the truck tried to overtake another truck, turned over and struck a coconut tree.
- Outcome — Mamador died; several others were injured.
- Criminal proceedings against the driver
- Prosecution — Procopio Macunat was prosecuted, convicted, and sentenced to indemnify the heirs of the deceased in Criminal Case No. 1491.
- Payment status — Macunat had not paid the indemnity to the heirs at the time of the Workmen's Compensation proceedings.
- Administrative proceedings before the Commission
- Initiation — Commission requested investigation on March 28, 1953.
- Public Defender proceedings — The Public Defender of Boac notified Geronimo Ma. Coll and general manager Eric Lenze to appear May 12 and May 29, 1953; only Coll appeared on May 29 and his sworn testimony was taken in question-and-answer form.
- Referee correspondence and company response — Referee Ramon Villaflor wrote the company on August 18, 1953 to comment on Coll's sworn declaration; the company, through its Vice President, denied liability under the Workmen's Compensation Law.
- Further investigation and opportunity t...(Subscriber-Only)
Issues:
- Procedural due process and evidence
- Whether petitioner was deprived of the opportunity to cross-examine adverse witnesses in violation of due process and thus the Commission proceedings are invalid.
- Effect of third‑party proceedings and settlement under Section 6
- Whether the prior prosecution, conviction, and sentence of Macunat, and an alleged amicable settlement between Macunat and the heirs, operate under Section 6 of the Workmen's Compensation Law to bar the heirs' claim against the employer.
- Employee misconduct and exclusion for *notorious negligence*
- Whether the deceased’s violation of the employer’s prohibition against riding haulage trucks constitutes *notorious negligence* that precludes recovery...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)