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’s employer and the owner of the truck involved, seeking to enforce the civil liability for the indemnities awarded in the criminal case.

ISSUE

Whether Luzon Brokerage Co., Inc. can be held 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. The Court ruled that while the offense was punished under a special law (the Revised Motor Vehicle Law), the civil obligations arising from the crime are governed by the Revised Penal Code as supplementary law, pursuant to Article 1092 of the Civil Code. Under Article 103 of the Revised Penal Code, employers are subsidiarily liable for the civil liabilities arising from crimes committed by their employees in the discharge of their duties. The Court also held that the indemnity of P500 for each deceased victim was proper, and the fact that two deceased were from the same family did not reduce the total indemnity, as the family suffered separate damages for each death.

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