G.R. No. L-33851 August 15, 1988
MARCOPPER MINING CORPORATION, petitioner, vs. HON. JESUS V. ABELEDA, Presiding Judge, Court of First Instance of Marinduque, EUFROCINO IGNACIO, URSULA MINAY and JUANITA ALMARIO VDA. DE IGNACIO, as guardian ad litem of the minor, ALANIE IGNACIO, respondents.

FACTS

Alfonso Ignacio, an employee of Marcopper Mining Corporation, was killed in a workplace accident on October 9, 1970. His widow, Juanita Ignacio, subsequently filed a claim under the Workmen’s Compensation Act. On December 18, 1970, she received the sum of P707.24 as full compensation for her husband’s death and executed a “Satisfaction of Claim,” waiving all other claims under the said law. Marcopper also voluntarily paid an additional P150.00, which the widow accepted.
Despite this settlement, the widow, her minor child, and the deceased’s parents later filed a civil case for damages against Marcopper in the Court of First Instance of Marinduque. They alleged that Ignacio’s death resulted from the corporation’s gross negligence due to a lack of safety measures. Marcopper moved to dismiss the complaint, arguing that the prior acceptance of full compensation under the Workmen’s Compensation Act barred a subsequent civil action under the Civil Code. The respondent judge denied the motion to dismiss, prompting Marcopper to elevate the matter to the Supreme Court via a petition for certiorari and prohibition.

ISSUE

Whether the widow’s acceptance of full death benefits under the Workmen’s Compensation Act precludes her from instituting a separate action for damages under the Civil Code arising from the same death.

RULING

Yes. The Supreme Court granted the petition and ordered the dismissal of the civil case. The Court resolved the basic issue by applying the rule established in Floresca v. Philex Mining Corporation, which clarified the previously confused jurisprudence. The Floresca doctrine holds that an injured party or the heirs of a deceased employee have a choice of remedies: they may either claim compensation under the Workmen’s Compensation Act or sue for damages under the Civil Code based on tort or quasi-delict. However, this choice is exclusive. The election of one remedy bars recourse to the other. Crucially, the acceptance of benefits under the chosen remedy conclusively precludes a subsequent claim under the alternate remedy.
The legal logic is grounded in the principle of estoppel and fair play. By opting to recover under the Workmen’s Compensation Act and, more definitively, by accepting the full compensation awarded and executing a satisfaction of claim, Juanita Ignacio and her minor child made a final election of remedy. They are therefore barred from pursuing the alternate course of action for damages under the Civil Code. The exception to this rule—where a claimant may still sue under the Civil Code based on supervening facts occurring after opting for compensation under the Act—was not present in this case. Consequently, having received full benefits, they could no longer maintain the civil complaint. The other ancillary issues regarding the capacity of parties were rendered moot by this resolution.