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

FACTS

Pedro Morales, an employee-driver of 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, sentencing him to imprisonment and ordering him to indemnify the families of the four deceased victims (Fidel Copiaco, Delfin Copiaco, Leonardo Reyes, and Juan Reyes) with P500 each. The civil indemnity could not be executed because Morales was 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 subsidiary civil liability for the indemnities awarded in the criminal case.

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. The Court ruled that even though the offense was punished 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, which applies suppletorily. The civil actions by the heirs were proper to enforce the civil obligations arising from the crime, pursuant to Article 1092 of the Civil Code. The Court also held that the indemnity of P500 for each deceased victim, totaling P2,000, was correct, rejecting the appellant’s claim that it should only be P500 per family (which would total P1,500, as two deceased were siblings), because the family of the two Copiaco brothers suffered double damage from the loss of two members.

AI Generated by Armztrong.