Case Summary (G.R. No. 46135)
Background of the Case
Pedro Morales was charged with quadruple homicide through reckless imprudence for driving a truck recklessly, causing the deaths of four individuals on April 24, 1935, in Manila. The court found him guilty under Section 67(d) of the Revised Motor Vehicle Law (Act No. 3992), sentencing him to imprisonment from three to six years and requiring him to pay the families of the deceased indemnities of P500 each. After Morales's insolvency prevented the payment of these indemnities, the heirs initiated civil actions against Luzon Brokerage Co., Inc., as the employer of Morales.
Civil Actions Filed
The heirs of the deceased individuals filed separate civil suits against Luzon Brokerage Co., Inc. in the municipal court of Manila, claiming indemnities based on the unresolved civil liability arising from the conviction of Morales. Each complaint sought to recover P500, the amount awarded in the criminal case, and additional damages in some cases due to the loss of their family members. The municipal courts ruled in favor of the plaintiffs, leading to the appeal by Luzon Brokerage Co., Inc.
Joint Trial and Ruling
The civil actions were consolidated and jointly tried in the Court of First Instance of Manila, which found Luzon Brokerage Co., Inc. subsidiarily liable for the indemnities originally imposed on Morales. The court affirmed the requirement that the corporation pay the families P500 each, plus legal interest and costs, referencing Articles 10 and 103 of the Revised Penal Code, which hold employers accountable for the actions of their employees conducted within their employment scope.
Challenges by the Defendant
In appealing the court's ruling, Luzon Brokerage Co., Inc. raised multiple arguments. Firstly, it contested the applicability of Article 103 of the Revised Penal Code to the Revised Motor Vehicle Law, claiming that the law's penalties did not entail civil indemnity as an accessory penalty. However, case law affirmed that the Revised Motor Vehicle Law constitutes a special penal law, making the Revised Penal Code supplementary to it.
Clarification on Civil Liability
The court clarified that the applicability of Article 100 of the Revised Penal Code solidifies civil liability for an individual who is criminally liable. The refusal of the defendant's argument was based on the premise that the indemnity claims were valid under the Civil Code and Penal Code provisions, extending to the families of the deceased, thus substantiating the civil obligations arising from the crime committed by Morales. Even without the indemnities awarded in the criminal case being valid, the plaintiffs' claims could still prosper under Article 1092 of the Civil Code.
Indemnity Amounts
The judgment awarded defendants a total of P2,000 for the deaths of the four victims, based on the precedent that each family, especially those suffering dual losse
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Case Overview
- This case involves a criminal conviction and subsequent civil liability regarding the tragic deaths of four individuals, resulting from an accident caused by Pedro Morales, a chauffeur employed by Luzon Brokerage Co., Inc.
- The case was decided on September 19, 1938, by the Supreme Court of the Philippines, with the decision affirming the civil liability of the defendant for indemnities owed to the heirs of the deceased.
Facts of the Case
- Pedro Morales was charged with quadruple homicide through reckless imprudence for an incident occurring on April 24, 1935, in Manila.
- Morales, while driving truck No. T-1179, operated the vehicle recklessly, leading to a collision with a carretela, resulting in the deaths of passengers Fidel Copiaco, Delfin Copiaco, Leonardo Reyes, and Juan Reyes.
- The trial court found him guilty and sentenced him to an indeterminate prison term of three to six years, along with an order to pay P500 to each family of the deceased.
Criminal Liability and Judgment
- The court's judgment was executed without appeal, making it final.
- However, upon execution of the civil aspect of the judgment, it was discovered that Morales was insolvent, prompting the heirs of the deceased to file civil suits against Luzon Brokerage Co., Inc., as the employer and owner of the truck involved in the accident.