Case Summary (G.R. No. 178454)
Procedural History
– May 1968: Philex moved to dismiss for lack of jurisdiction, citing exclusive coverage under the Workmen’s Compensation Act.
– June 27, 1968: CFI dismissed the complaint.
– Sept. 23, 1968: CFI reinstated the case.
– Dec. 16, 1968: CFI again dismissed, ruling that the Workmen’s Compensation Commission had exclusive original jurisdiction.
– April 1976: SC resolved to hear the petition.
Issues
Whether heirs may pursue a civil action for damages under the Civil Code in regular courts or are limited to remedies under the Workmen’s Compensation Act.
Petitioners’ Arguments
– Complaint alleges causes of action under Civil Code articles on quasi–delict, not the Compensation Act.
– They seek actual, moral, and exemplary damages for employer’s bad faith and gross negligence.
Respondent’s Arguments
– Sections 5 and 46 of the Compensation Act grant exclusive rights and jurisdiction to the WCC, excluding other remedies against the employer.
– Employer’s negligence merely permits additional 50% compensation under Section 4-A of the Act.
Amici Curiae Positions
– Divergent views: exclusive remedy (Undersec. Bocobo, Justice Lazaro), purely selective remedy (Atty. Lazaro), or exclusive remedy once elected (Atty. Bacungan).
Court’s Analysis on Jurisdiction and Nature of Claims
The SC held that the tort claim under Civil Code is distinct from a compensation claim. The complaint does not invoke the Compensation Act; it alleges breach of contract and quasi-delict based on gross negligence. Civil Code remedies for actual, moral, and exemplary damages are not provided by the Compensation Act, which only awards fixed compensation benefits.
Choice of Remedies Doctrine
Relying on Pacafia v. Cebu Autobus Co., the SC ruled that an injured worker or heirs may choose either compensation under the Compensation Act or bring a civil action for higher damages, but not both simultaneously. The initial election under ignorance of employer’s negligence is not binding; hence, those who first filed compensation claims may still pursue civil damages once aware of facts constituting gross negligence. Any compensation already received must be deducted from civil awards.
Constitutional Principles and Legislative Interpretation
The Court emphasized social justice mandates o
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Facts of the Case
- Petitioners are heirs of five Philex Mining employees who perished in an underground cave-in at Tuba, Benguet on June 28, 1967.
- The complaint alleges Philex’s gross and reckless negligence: failing to observe government safety regulations, allowing water and mud to accumulate, saturating weakened rock columns, and precipitating a collapse that buried workers.
- Out of 48 underground workers, 5 escaped, 22 were rescued within seven days, and 21—including the petitioners’ decedents—were left trapped and perished.
Procedural History
- May 14, 1968: Philex moves to dismiss for lack of jurisdiction, invoking the Workmen’s Compensation Act’s exclusivity.
- May 27, 1968: Petitioners oppose, characterizing their cause of action as Civil Code damages (actual, moral, exemplary).
- June 27, 1968: Trial court dismisses for exclusive remedy under the Compensation Act.
- Sept 23, 1968: Upon reconsideration, trial court allows Philex to answer.
- Dec 16, 1968: Trial court again dismisses for lack of jurisdiction, reaffirming exclusive original jurisdiction of the Compensation Commission.
- Petitioners seek review by the Supreme Court.
Issues Presented
- Whether the trial court erred in dismissing the Civil Code action for lack of jurisdiction.
- Whether there is a clear distinction between (a) claims for compensation under the Workmen’s Compensation Act and (b) claims for damages under the Civil Code based on gross negligence.
- Whether the remedy under the Compensation Act is exclusive, selective, or cumulative with a civil action for damages.
Petitioners’ Contentions
- Their complaint is grounded in Civil Code provisions on quasi-delict and breach of contract with bad faith (Arts. 2176, 2178, 1173, 2201, 2231).
- Allegations of gross negligence and deliberate safety failures place this suit outside compensation claims.
- By filing a motion to dismiss, Philex admitted petitioners’ factual allegations, including criminal negligence.
Respondents’ Contentions
- Sections 5 and 46 of the Workmen’s Compensation Act grant exclusive remedy to the Compensation Commission, barring all other claims