G.R. No. 46135, September 19, 1938
ALFREDO COPIACO, ET AL., plaintiffs-appellees, vs. LUZON BROKERAGE CO., INC., defendant-appellant.

FACTS

Pedro Morales, a chauffeur employed by Luzon Brokerage Co., Inc., was convicted in a criminal case for quadruple homicide through reckless imprudence under the Revised Motor Vehicle Law (Act No. 3992). The judgment became final and included an order for Morales to indemnify the family of each deceased victim with P500. Upon execution, Morales was found insolvent. The heirs of the four deceased victims subsequently filed separate civil actions against Luzon Brokerage Co., Inc., as Morales’ employer and the owner of the truck involved, seeking to enforce the civil liability for the indemnities awarded in the criminal judgment.

ISSUE

Whether Luzon Brokerage Co., Inc. is subsidiarily civilly liable for the indemnities awarded in the criminal judgment against its insolvent employee, Pedro Morales.

RULING

Yes. The Supreme Court affirmed the lower court’s judgment holding Luzon Brokerage Co., Inc. subsidiarily liable. The Court ruled that even assuming the award of indemnity in the criminal case was not expressly authorized under the special law (Act No. 3992), the civil actions could proceed under Article 1092 of the Civil Code, which provides that civil obligations arising from crimes are governed by the Penal Code. Applying Article 103 of the Revised Penal Code on subsidiary civil liability, the employer is subsidiarily liable for the civil liabilities arising from the employee’s criminal act. The amount of P500 for each deceased victim was within the established jurisprudential range for death indemnity. The Court also held that the heirs of the two deceased Copiaco brothers were entitled to separate indemnities (totaling P1,000) as they suffered distinct damages from the loss of two family members.

AI Generated by Armztrong.