G.R. No. L-15692; May 31, 1961
ENGRACIA ALARCON, plaintiff-appellant, vs. JUAN ALARCON, defendant-appellee.

FACTS

Plaintiff Engracia Alarcon, mother of the deceased Urzino Azaña, filed an action for damages against defendant Juan Alarcon under Article 1711 of the Civil Code. The defendant, a school teacher, hired Urzino to dig a well on his land. During the excavation, Urzino fainted inside the hole and died of asphyxia. Efforts to rescue him were hindered by obnoxious fumes in the well. The defendant admitted hiring Urzino but denied liability.
The Court of First Instance of Camarines Sur dismissed the complaint. It ruled that the defendant, not being an owner of an enterprise or an employer in business or industry, was not liable under Article 1711, as the death was purely accidental. The plaintiff appealed, raising a pure question of law on the applicability of Article 1711 to the defendant’s status.

ISSUE

Whether the defendant, a private individual who hired laborers for a purely personal and casual project (digging a well), falls under the category of “other employers” in Article 1711 of the Civil Code, thereby obliging him to pay compensation for the accidental death of a laborer.

RULING

No. The Supreme Court affirmed the dismissal, holding that Article 1711 does not apply to the defendant. The legal logic proceeds from statutory construction and legislative intent. Article 1711 obliges “owners of enterprises and other employers” to pay compensation even for accidental deaths arising from employment. Applying the principle of ejusdem generis, the phrase “other employers” must be interpreted in a class analogous to “owners of enterprises.” This refers to persons engaged in business, industry, or trade, who contract services as part of their occupational undertaking.
The Court examined the context of the Civil Code provisions, noting they were designed to implement social justice in labor-capital relations, using terms like “capital,” “management,” and “industrialist.” Furthermore, Article 1711 is philosophically aligned with the Workmen’s Compensation Act (Act No. 3428), which by its own terms excludes employees whose work is “purely casual and is not for the purposes of the occupation or business of the employer.” The defendant, a school teacher hiring for a personal domestic need, was not engaged in any business or enterprise. Thus, the employment was purely casual and outside the scope of both Article 1711 and the special laws on compensation. Liability cannot be imposed for a purely fortuitous event under these circumstances.