Case Digest (G.R. No. 236263) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On November 2, 2011, Romeo S. Ellao, a 33-year-old company driver employed by Oceanmarine Resources Corporation (petitioner), was shot dead by two unidentified motorcycle-riding assailants while driving along Bayview Drive in Parañaque City. Romeo had been transporting company funds to several banks in Pasay and Parañaque. Following his death, his common-law partner, Jenny Rose G. Nedic (respondent), sent petitioner a written demand for P3,382,560.00 as lost future income on behalf of her minor son, Jerome. Petitioner denied liability. On April 16, 2012, respondent filed a complaint under Article 1711 of the Civil Code for “Lost Future Income” of P3,383,640.00. The Regional Trial Court dismissed the complaint for failure to prove negligence of the employer. On December 19, 2017, the Court of Appeals reversed, holding that Article 1711 requires no negligence and automatically attaches when death occurs in the course of employment, and awarded P1,409,850.00 as actual damages for l Case Digest (G.R. No. 236263) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Employment
- Petitioner: Oceanmarine Resources Corporation, employer of Romeo S. Ellao.
- Respondent: Jenny Rose G. Nedic, on behalf of her minor son Jerome Nedic Ellao, heir of deceased Romeo.
- Circumstances of Death
- On 02 November 2011, Romeo was instructed by petitioner to drive company personnel to various bank transactions in Pasay City and Parañaque City.
- While driving along Bayview Drive, two motorcycle-riding assailants stopped the vehicle, shot Romeo to death, and fled with a bag of company money.
- Pre-trial Correspondence
- Respondent’s counsel demanded P3,382,560.00 for loss of future income; petitioner denied liability as claimant was not yet guardian.
- Respondent filed suit under Article 1711, Civil Code, claiming P3,383,640.00 for lost future income of Romeo.
- Proceedings Below
- Regional Trial Court (Parañaque City, 22 Sep 2014): Dismissed complaint for failure to prove employer negligence and causal connection.
- Court of Appeals (19 Dec 2017): Reversed RTC, held Article 1711 still valid under Candano, awarded P1,409,850.00 for loss of earning capacity plus attorney’s fees, costs, and interest.
- Petitioner elevated case to the Supreme Court via Petition for Review on Certiorari (G.R. No. 236263).
Issues:
- Repeal and Prevalence
- Has Article 1711 of the Civil Code been impliedly repealed by Title II, Book IV of the Labor Code?
- If not repealed, does the later special compensation scheme of the Labor Code prevail over the general Civil Code provision?
- Application of Candano
- Did the Court of Appeals correctly apply Candano Shipping Lines, Inc. v. Sugata-on to uphold actions under Article 1711?
- Should Candano’s endorsement of Article 1711 and the Villa Rey formula be retained or abandoned?
- Election of Remedies and Exclusivity
- Is the remedy of compensation under the Labor Code exclusive, or may an employee choose a civil suit for damages under the Civil Code?
- Does receipt of Social Security System (SSS) death benefits bar a subsequent Civil Code claim?
- Distribution of Award
- Should an illegitimate minor heir’s award for loss of future income be shared with the deceased’s legitimate ascendants under Article 991, Civil Code?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)