G.R. No. 46135 , September 19, 1938
ALFREDO COPIACO, ET AL. vs. LUZON BROKERAGE CO., INC. (Consolidated with G.R. Nos. 46136, 46137, 46138)

FACTS

Pedro Morales, a chauffeur of Luzon Brokerage Co., Inc., was convicted in a criminal case for quadruple homicide through reckless imprudence under the Revised Motor Vehicle Law. The judgment, which became final, sentenced him to imprisonment and to indemnify the family of each of the four deceased victims (Fidel Copiaco, Delfin Copiaco, Leonardo Reyes, and Juan Reyes) in the sum of P500. Upon execution, Morales was found insolvent. The heirs of the deceased then filed separate civil actions against Luzon Brokerage Co., Inc., as Morales’s employer and the owner of the truck involved, seeking to enforce the indemnities awarded in the criminal judgment.

ISSUE

Whether Luzon Brokerage Co., Inc. is subsidiarily liable for the civil 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. Although the criminal conviction was under a special law (the Revised Motor Vehicle Law), the subsidiary civil liability of the employer is governed by Article 103 of the Revised Penal Code, applied supplementally. Furthermore, civil obligations arising from crimes are governed by the Penal Code under Article 1092 of the Civil Code. The indemnity of P500 for each deceased victim was within the judicial discretion for death indemnity. The employer’s liability extends to the full P2,000 (P500 for each of the four deceased), not merely P1,500 for the three families, as the family of the two Copiaco children suffered double damage from the loss of two members.

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