Jahara v. Mindanao Lumber
REITERATIONFacts
The Antecedents: Moro Sapturani, a workman employed by laborers who cut timber within the defendant company's concession, was killed when he was run over by the last car of the defendant's moving train. The defendant company paid the contractor for the timber and firewood delivered. Procedural History: The plaintiffs, heirs of the deceased Sapturani, filed an action in the Court of First Instance of Zamboanga for compensation under Act No. 3482 (Workmen's Compensation Act). The trial court absolved the defendant company from the complaint. The Petition: The plaintiffs appealed the trial court's decision, assigning several errors, primarily concerning the court's findings on the cause of the accident and the deceased's alleged negligence.
Issue(s)
Whether the trial court erred in finding that Moro Sapturani's death was due to his own 'notorious negligence' under Section 4 of Act No. 3428. Whether the defendant company can be held liable for compensation despite the deceased's attempt to board a moving train.
Ruling
The Supreme Court affirmed the decision of the trial court, absolving the defendant company from liability. The Court found that the deceased workman acted with notorious negligence in attempting to board a moving train, which directly caused his death.
Ratio Decidendi
On Issue 1: The Supreme Court held that the trial court's conclusion regarding Sapturani's notorious negligence was supported by a preponderance of the evidence. The Court found the version of the accident provided by the defense witnesses more probable than the version provided by the plaintiffs' witnesses. It was established that Sapturani attempted to board the rear platform of a car while it was in motion, specifically moving backwards. This act was inherently dangerous and the risk of falling was immediate and obvious. The Court emphasized that Sapturani could have easily avoided the train by simply stepping off the rails, but he chose to attempt a reckless maneuver. Consequently, his actions constitute 'notorious negligence' within the meaning of the law. On Issue 2: Under Section 4, subdivision 3 of Act No. 3428 (the Workmen's Compensation Act), no action for the recovery of compensation shall prosper when the accident is due to the 'notorious negligence' of the workman. Since the Court determined that Sapturani's death was the direct result of his own reckless attempt to board a moving train, the statutory exception applies. Even if the defendant company fell within the coverage of the Act based on its gross annual income, the claim is barred by the deceased's own conduct. The Court reiterated that the purpose of the WCA is to provide compensation for industrial accidents, but it does not insure workmen against the consequences of their own manifest recklessness. Thus, the employer cannot be made liable for the payment of compensation in this case.
Main Doctrine
An employer is not liable for compensation under the Workmen's Compensation Act when the accident causing the employee's death is due to the employee's own notorious negligence.