Zamora v. Rosales
REITERATIONFacts
The Antecedents: Virginia Clareza and her children filed a civil case against Benjamin A. Rosales and Amado A. Dimayuga, claiming damages for the death of Juan Luno, who was driving a taxicab owned by Felipe J. Zamora and collided with by the defendant Rosales due to alleged reckless negligence. The defendants claimed the incident was due to the deceased's own negligence and filed a counterclaim for damages. Procedural History: Felipe J. Zamora, owner of the taxicab, filed a motion for leave to intervene and/or be substituted for the plaintiffs. He averred that he had paid P4,000.00 to the heirs of the deceased as compensation under the Workmen's Compensation Act and was therefore subrogated to their rights against the defendants. He prayed for various damages, including the P4,000.00 paid. The Petition: The defendants moved to dismiss the complaint in intervention, arguing that since the plaintiffs had already recovered compensation from the intervenor, they had no further cause of action, and thus, no basis for intervention. The lower court dismissed both the complaint and the complaint in intervention. A motion for reconsideration was denied, leading to this appeal by intervenor Zamora.
Issue(s)
Whether the lower court correctly dismissed the complaint in intervention on the ground that the original plaintiffs' cause of action had ceased upon receipt of compensation from the intervenor.
Ruling
The Supreme Court set aside the order of dismissal, substituted intervenor Felipe J. Zamora for the original plaintiffs Virginia Clareza and her children, and admitted the complaint in intervention. The case was returned to the lower court for further proceedings.
Ratio Decidendi
On Issue 1: The Supreme Court acknowledged the fundamental principle that intervention is never an independent action but is ancillary and supplemental to an existing litigation, as reiterated in Garcia v. David, et al. and Reliance Commercial Enterprises, Inc. vs. Board of Tax Appeals. The Court initially agreed that if the original plaintiffs' right to sue ceased due to the payment of compensation by the intervenor, in accordance with Section 6, Act 3812 as amended by Republic Act No. 772, then the original action could no longer continue. Consequently, the right of an intervenor, being merely in aid of the original party's right, would also cease if the original right no longer existed. However, the Court clarified that despite the cessation of the original plaintiffs' direct cause of action against the defendants, the unique circumstances involving subrogation warranted a different procedural treatment to ensure the continuation of the claim and avoid a multiplicity of suits. The Court held that the coming in of the intervenor should be allowed under Section 20 of Rule 3 of the Rules of Court, which provides that in case of any transfer of interest, the action may be continued by or against the original party, unless the court upon motion directs the person to whom the interest is transferred to be substituted in the action or joined with the original party. Under Section 6 of the Workmen's Compensation Act, as amended, the employer who paid compensation "shall succeed the injured employee to the right of recovery from such person what he paid." The Court definitively ruled that the intervenor, as the employer, could be substituted as the party plaintiff, especially since he had specifically prayed for this substitution and presented necessary amendments to the original complaint. This procedural allowance was deemed to subserve the policy of the Rules of Court by avoiding multiplicity of suits, as the right being pursued by the intervenor was the same right of the original party, merely transferred to the employer through subrogation.
Main Doctrine
An employer who pays compensation to the heirs of a deceased employee is subrogated to the employee's right of recovery against the negligent third party and may be substituted as plaintiff in the action for damages, to avoid multiplicity of suits.