Murillo v. Mendoza
REITERATIONFacts
The Antecedents: Plaintiffs, as widow and minor children of the deceased Octavio Madrid, filed an action to recover compensation under the Workmen's Compensation Act. Octavio Madrid was employed as first officer of the S.S. "Marie," owned and operated by the defendant Alfredo Mendoza. While the vessel was plying off Palanan Point, Isabela, it was struck by a typhoon, causing it to sink and resulting in the death of all officers and crew, including Octavio Madrid. The plaintiffs were totally dependent on the deceased. Procedural History: The parties submitted the case on a stipulation of facts. The lower court rendered judgment ordering the defendant to pay the plaintiffs P3,000 with legal interest and costs. The defendant appealed. The Petition: The defendant appealed the decision, raising several assignments of error, primarily concerning the compensability of the accident under the Workmen's Compensation Act.
Issue(s)
Whether the plaintiffs proved that the defendant's gross income during the year preceding the accident amounted to P20,000 or more. Whether the accident, caused by a typhoon (force majeure), is compensable under the Workmen's Compensation Act. Whether the death of Octavio Madrid arose out of his employment. Whether the Workmen's Compensation Act abrogates provisions of the Code of Commerce regarding shipowner liability.
Ruling
The Supreme Court affirmed the decision of the lower court, ordering the defendant to pay the plaintiffs the sum of P3,000 with legal interest and costs. The Court held that the accident is compensable under the Workmen's Compensation Act.
Ratio Decidendi
On the issue of proving gross income: The Court reiterated the doctrine established in Rolan vs. Perez, holding that the plaintiff is not required to allege or prove that the employer's gross income met the threshold for the Workmen's Compensation Act. Instead, this is a defense that the defendant must allege and establish. The amendment to Section 39(d) of Act No. 3428 by Act No. 3812 removed the necessity for the plaintiff to prove the gross income, as the omission of the phrase regarding the minimum gross income meant that the requirement no longer applied from the amendment's effective date. Therefore, the first assignment of error was overruled. On the compensability of accidents caused by force majeure: The Court held that the Workmen's Compensation Act covers maritime accidents occurring in Philippine waters, as provided in Section 38 of Act No. 3428, which includes employees engaged in interisland trade. The Act abrogates common law and Civil Code doctrines regarding fault or negligence, imposing liability without fault. Therefore, an accident caused by a typhoon, a force majeure or fortuitous event, is compensable if it arises out of and in the course of employment. The Court cited Enciso vs. Dy-Liacco to support the principle that the Act was enacted to provide compensation for accidental calamities incidental to employment, regardless of employer fault. On whether the death arose out of employment: The Court defined "arising out of the employment" as a causal connection between the conditions of work and the injury. It found that Octavio Madrid, as first officer, was contracted to render services in the vessel, including during storms. He was aware that in case of a typhoon, his services would be required to a higher degree to save the vessel. Therefore, his death, while fulfilling his duties during a typhoon, had a causal connection to the conditions of his employment, making it compensable. The Court noted that while the typhoon was the immediate cause, the conditions of employment exposed him to a greater risk than usual, thus establishing the causal relation. On the abrogation of Code of Commerce provisions: The Court opined that the Workmen's Compensation Act creates a new source of compensation independent of fault or negligence, and its provisions govern independently of other laws, including the Civil Code and the Code of Commerce. The Act was enacted in abrogation of other existing laws, based on the theory that the economic loss from an employee's injury should be borne by the industry. Therefore, even if Article 643 and 837 of the Code of Commerce limited shipowner liability, the Workmen's Compensation Act's provisions for compensation would still apply. The Court acknowledged potential losses for shipowners but emphasized humanity and civilization demanding protection for workmen.
Main Doctrine
Accidents occurring in the interisland trade, even if caused by force majeure or fortuitous events, are compensable under the Workmen's Compensation Act if they arise out of and in the course of employment, as the Act abrogates common law doctrines of negligence and imposes liability without fault.