Case Summary (G.R. No. 198662)
Factual Background
Melquiades Sugata-on was employed by Candano Shipping on March 7, 1994, and went missing following the sinking of the M/V David, Jr. on March 27, 1996. The sinking occurred under severe weather conditions that ultimately led to the vessel's tilting and eventual sinking, claiming the lives of one crew member and leaving seven others missing, including Melquiades.
Procedural History
After refusing to compensate for her husband’s alleged death, Florentina Sugata-on filed for indemnity against Candano Shipping before the Regional Trial Court (RTC) on January 31, 1997. The RTC ruled in favor of Florentina, ordering Candano Shipping to pay various damages, including compensation for loss of earnings. This decision was later modified by the Court of Appeals, which reduced the actual damages but eliminated moral and exemplary damages.
Applicable Law
The legal basis for Florentina’s claim is Article 1711 of the New Civil Code, which imposes liability upon employers for the death of employees in the course of employment, regardless of whether the circumstances of the death were fortuitous. The case also invokes the application of Article 194 of the Labor Code concerning death compensation for employees.
Issues Presented
Candano Shipping presented multiple issues for review, including whether Article 194 of the Labor Code applies to claims made under Article 1711 of the Civil Code and whether the appellate court had jurisdiction over the case when applying provisions of the Labor Code.
Court’s Analysis
The Supreme Court first confirmed that the factual findings regarding Melquiades’ presumed death due to the sinking incident are settled and uncontroverted. It highlighted the validity of Florentina's claim under the Civil Code, clarifying that selection of remedies is permissible and that pursuing compensation under the Civil Code does not preclude recovery under the Labor Code.
The Supreme Court also discussed the damages awarded and concluded that while actual damages were warranted, the awards for moral and exemplary damages were not supported by sufficient justification. The court reiterated the distinction between the theories of compensation under the Workers' Compensation Act and damages under the Civil Code.
Computation of Damages
The Court adopted the formula for computing loss of earning capacity outlined in the case of Villa Rey Transit, adjusted to reflect Melquiades' monthly income and reasonable living expenses. To determine the net earning capacity, the Court applied
...continue readingCase Syllabus (G.R. No. 198662)
Case Background
- Petitioner: Candano Shipping Lines, Inc.
- Respondent: Florentina J. Sugata-on
- G.R. No.: 163212
- Date of Decision: March 13, 2007
- Nature of Petition: This is a Petition for Review on Certiorari under Rule 45 of the Revised Rules of Court, seeking to reverse and set aside the decision of the Court of Appeals dated May 23, 2003, and its resolution dated April 1, 2004.
- Central Issue: Whether Candano Shipping is liable for the death of Melquiades Sugata-on, and the appropriate computation of damages owed to his widow, Florentina.
Factual Antecedents
- Employment: Melquiades Sugata-on was employed as a Third Marine Engineer by Candano Shipping, with a monthly salary of P7,800.
- Incident: On March 25, 1996, the cargo vessel M/V David, Jr. set sail with Melquiades and 20 crew members. On March 27, 1996, the vessel encountered severe weather, leading to its sinking at Bakulin Point, Lianga Bay, Surigao del Sur.
- Casualties: Of the crew, twelve survived, one died, and seven were reported missing, including Melquiades Sugata-on.
- Claim for Benefits: Upon learning of her husband's fate, Florentina sought death benefits from Candano Shipping but was denied, prompting her to file a lawsuit on January 31, 1997.
Procedural History
- Initial Court Action: Florentina filed for indemnity based on Article 1711 of the New Civil Code, which holds employers liable for employee deaths occurring in the course of employment.
- Defendant's Argument: Candano Shipping contended that Melquiades' death was not established as he was merely reported missing, arguing the case was premature.
- RTC Decision: The Regional Trial Court ruled in favor of Florentina, applying Article 391 of the New Civil Code, which recognizes presumptive death after four years of absence, ordering Candano Shipping to pay P988,400.00 as actual damages, alongside moral and exemplary damages, and attorney's fe