Caunan v. Compañia General de Tabacos de Filipinas
REITERATIONFacts
The Antecedents: Benigna Caunan, mother of the deceased Gregorio Afable, filed an action under the Workmen's Compensation Act against Compañia General de Tabacos de Filipinas (the company) for compensation due to Afable's death. The company maintained a branch selling rice and cigarettes, which was later closed, and the premises were used exclusively for copra purchase. The ground floor served as an office, and the first story as employee quarters. Employees resided there not as partial compensation but as caretakers. Procedural History: The Court of First Instance of Tayabas dismissed the complaint. The plaintiff appealed the decision. The Petition: The plaintiff appealed, assigning errors in the trial court's holding that the deceased laborer was guilty of "notorious negligence" and in not awarding compensation.
Issue(s)
Whether the deceased workman, Gregorio Afable, was guilty of "notorious negligence" under Section 4 of Act No. 3428, thereby barring his heirs from recovering compensation for his death.
Ruling
The Supreme Court affirmed the judgment of the Court of First Instance, dismissing the complaint and holding that the deceased laborer was guilty of notorious negligence, thereby disentitling his legal representative to compensation. No costs were awarded.
Ratio Decidendi
On Issue 1: The Court ruled that Gregorio Afable was guilty of "notorious negligence." The evidence established that Afable was an experienced carpenter who had been working on the building for a month and was familiar with the roof's condition. On the day of the accident, he was aware that rain had made the galvanized iron sheets slippery. Despite this obvious hazard, he wore rubber-soled shoes and stepped onto a loose, unnailed sheet of iron. The Court reasoned that the exercise of ordinary care and precaution would have allowed a careful workman to avoid the fatal step. Consequently, this conduct was characterized as "evident and manifest" negligence, which falls under the legal designation of "notorious negligence" under Section 4 of Act No. 3428. Because notorious negligence is a statutory ground for denying indemnity, the plaintiff's claim for compensation was properly rejected.
Main Doctrine
An employee's death resulting from his own notorious negligence, as defined under the Workmen's Compensation Act, does not entitle his legal representative to compensation.