G.R. No. L-6472, March 7, 1912
MANUELA ROSARIO, ET AL., plaintiffs-appellees, vs. THE MANILA RAILROAD COMPANY, defendant-appellant.

FACTS

Joaquin Fontanilla, a foreman for the Manila Railroad Company, died in a workplace accident on January 8, 1909. While riding on a railroad car during loading/unloading operations, the car, after being uncoupled from a locomotive on an incline, rolled down and collided with another car, causing Fontanilla to fall and be fatally crushed. His widow, Manuela Rosario, initially filed a complaint for damages on behalf of herself and their six minor children, alleging negligence by the company’s employees (e.g., improper uncoupling on a slope). The company denied negligence, claiming the accident resulted from Fontanilla’s own imprudence. During proceedings, Manuela Rosario withdrew her personal claim, and the company argued this withdrawalbased on a prior sworn statement she made admitting the accident was due to her husband’s imprudenceshould bar the entire suit, including the children’s claims. The trial court initially dismissed the case but later reopened it. After trial, it awarded P2,500 in damages to the minor children. The company appealed, contending that the mother’s withdrawal and sworn statement prejudiced the children’s rights.

ISSUE

1. Whether Manuela Rosario’s withdrawal of her personal claim and her sworn statement admitting her husband’s imprudence barred the minor children’s independent action for damages.
2. Whether a parent, as natural guardian, can compromise or renounce the property rights or claims for indemnity of minor children without judicial authorization.

RULING

The Supreme Court AFFIRMED the trial court’s judgment awarding damages to the minor children.

1. The minor children’s right to indemnity is independent and not affected by the mother’s actions. The cause of action for damages arising from Fontanilla’s death belonged separately to each heir. Manuela Rosario’s withdrawal of her own claim and her extrajudicial sworn statement did not extinguish or prejudice the distinct rights of her minor children to seek indemnity for their father’s death.

2. A parent as natural guardian cannot renounce or compromise the property rights of minor children without court approval. Under Section 553 of the Code of Civil Procedure, a natural guardian (mother, in the father’s absence) has custody and care of the minor but does not have authority over the minor’s property or rights unless authorized by the court. The law prohibits parents or guardians from selling property, transferring rights, or compromising interests of minors without prior judicial sanction, a protection against potential fraud. Thus, Manuela Rosario had no legal power to renounce her children’s claim for indemnity through her sworn statement or withdrawal.

The Court found the company liable for negligence based on the evidence, and the minor children were entitled to damages. The mother’s acts did not bind the children, and the trial court correctly proceeded with their suit.