G.R. No. L-6869 May 27, 1955
SOLEDAD BELANDRES, plaintiff-appellant, vs. LOPEZ SUGAR CENTRAL MILL CO., INC., defendant-appellee.

FACTS

The plaintiff-appellant, Soledad Belandres, filed an action to recover damages for the death of her son, Querubin Villa, a train conductor employed by the defendant-appellee, Lopez Sugar Central Mill Co., Inc. The complaint alleged that on May 5, 1952, Villa died due to a derailment of empty cars he was riding on, which was caused by the negligence of the defendant’s employees (engine driver, superintendent, brakeman, and inspector). The defendant, in its answer, admitted Villa was its employee and died from a derailment but denied negligence, alleging it was Villa’s duty to ensure the tracks were clear and that he failed to notice pieces of iron on the rails placed by a third party. After the parties entered into a partial stipulation of facts (noting Villa died from a derailment caused by an obstacle on the rails) and the plaintiff presented her evidence, the defendant moved to dismiss the case on the ground of lack of jurisdiction. The lower court granted the dismissal, holding that the claim was essentially one for workmen’s compensation under special laws ( Act No. 3428 , as amended), citing an alleged admission by plaintiff’s counsel to that effect and Article 2196 of the Civil Code. The plaintiff appealed this dismissal.

ISSUE

Whether the lower court erred in dismissing the case for lack of jurisdiction, holding that the plaintiff’s action was one for workmen’s compensation under special laws rather than an action for damages based on negligence under the Civil Code.

RULING

Yes, the lower court erred. The Supreme Court reversed the dismissal and remanded the case for continuation of the trial. The Court held that the subject matter of a case is determined by the nature and character of the pleadings and issues submitted by the parties, not by what action a party might be entitled to bring under the facts and law. The plaintiff’s complaint expressly sought damages under Articles 2176 and 2180 of the Civil Code based on allegations of fault or negligence of the defendant’s employees. It did not allege that the death was due to an accident in the course of employment as defined in the Workmen’s Compensation Act. Therefore, the lower court had jurisdiction over the subject matter as an action for damages. The Court further ruled that any alleged admission by plaintiff’s counsel that the action was for workmen’s compensation was beyond the scope of the attorney’s authority, as such an admission pertains to the cause of action or subject matter, which is within the exclusive control of the client, not to procedural matters within the attorney’s control. The lower court should have proceeded to decide the case on its merits based on the issues framed by the pleadings.