Heirs of Marcelo Generoso v. Universal Textile Mills, Inc.
REITERATIONFacts
The Antecedents: Marcelo Generoso, an employee of Universal Textile Mills, Inc., was fatally stabbed by his co-employee, Antonio Lebantino, while Lebantino was performing his duties. Lebantino was convicted of homicide and sentenced to pay P6,000.00 as indemnity to Generoso's heirs. Lebantino was unable to pay the indemnity due to insolvency, and the writ of execution against him was returned unsatisfied. Universal Textile Mills, Inc. had already paid P5,279.36 to Generoso's heirs as workmen's compensation. Procedural History: The heirs of Marcelo Generoso sued Universal Textile Mills, Inc. for the subsidiary civil liability under Article 103 of the Revised Penal Code. The Court of First Instance of Manila ordered the corporation to pay the indemnity of P6,000.00 plus P1,000.00 as attorney's fees. The Petition: Universal Textile Mills, Inc. appealed the decision, arguing that its payment of workmen's compensation barred any further claim against it, particularly the subsidiary civil liability under the Revised Penal Code.
Issue(s)
Whether the employer's payment of workmen's compensation to the heirs of an employee killed by a co-employee extinguishes the employer's subsidiary civil liability under Article 103 of the Revised Penal Code. Whether the heirs' claim for workmen's compensation constitutes an election of remedy that bars them from claiming subsidiary civil liability from the employer; and the implications of the employer's subrogation rights.
Ruling
The Supreme Court reversed and set aside the decision of the trial court, dismissing the claim of the heirs of Marcelo Generoso for civil indemnity against Universal Textile Mills, Inc.
Ratio Decidendi
On the issue of whether the employer's payment of workmen's compensation extinguishes subsidiary civil liability: The Court held that the employer's payment of workmen's compensation to the heirs of the deceased employee extinguished its subsidiary civil liability under Article 103 of the Revised Penal Code. This is because Sections 5 and 6 of the Workmen's Compensation Law and Articles 102 and 103 of the Revised Penal Code are statutes in pari materia and should be construed together. Section 5 explicitly states that the rights and remedies granted by the Workmen's Compensation Act exclude all other rights and remedies against the employer under other laws. Therefore, by paying workmen's compensation, the employer fulfilled its obligation, and the heirs could not claim further from it. On the issue of election of remedies and subrogation: The Court affirmed that the heirs' claim for workmen's compensation constituted an election of remedy, which barred them from pursuing other remedies against the employer. Section 6 of the Workmen's Compensation Law provides that an injured employee has the option to either claim compensation from the employer or sue the third party responsible for the injury. Having opted for workmen's compensation, the heirs are bound by this election and are estopped from claiming other remedies, such as the subsidiary civil liability under the Revised Penal Code. This principle prevents double recovery for the same injury, as intended by law, similar to the provision in Article 2177 of the Civil Code. The Court clarified that by paying workmen's compensation, the employer is subrogated to the rights of the injured employee's heirs to recover from the guilty party (Lebantino) what the employer paid. Instead of being liable for the indemnity, the employer, as subrogee, is entitled to recover it from the convicted killer of the employee. This aligns with the proviso in Section 6 of the Workmen's Compensation Law, which allows the employer to recover from the third party what it paid, with any excess to be delivered to the employee or entitled persons.
Main Doctrine
An employer who has paid workmen's compensation to the heirs of an employee killed by a co-employee is not liable to pay the subsidiary civil liability under Article 103 of the Revised Penal Code, as the payment of workmen's compensation extinguishes the employer's obligation, and the heirs' claim for workmen's compensation constitutes an election of remedy that bars other claims against the employer.