Held
Angel may still file a complaint against CCC in the Regional Trial Court to seek damages under the Civil Code only if there are supervening facts or developments, such as the later discovery of CCC's negligence, that were unknown to her at the time she filed and accepted death benefits from the SSS under Article 179 of the Labor Code. Otherwise, her acceptance of State Insurance Fund benefits generally precludes a subsequent civil action for the same incident.
Explanation
Article 179 of the Labor Code provides that the liability of the State Insurance Fund (such as the SSS) is exclusive and in place of all other liabilities of the employer to the employee or his dependents. This means that when death benefits are paid under the Labor Code's compensation scheme, the employer is generally shielded from further civil liability for damages arising from the same injury or death.
The Supreme Court has clarified that the employee or his heirs have a choice between two remedies: either to claim the fixed compensation benefits under the Workmen's Compensation Act (now under the Labor Code) or to sue the employer for damages under the Civil Code based on negligence or fault. However, once the claimant chooses and accepts one remedy, they waive the other. This is to prevent double recovery for the same injury.
The Court has allowed an exception where new facts or developments arise after the first remedy was chosen, but this is a narrow exception and does not apply if the claimant was aware of the employer's negligence at the time of filing the compensation claim.
Application to the facts
Angel, as the widow of Dante, has already filed a claim for death benefits with the SSS under Article 179 of the Labor Code, and the SSS granted her claim. By accepting these benefits, Angel has generally chosen the remedy under the Labor Code's compensation scheme. However, if there are supervening facts or developments, such as the later discovery of CCC's negligence, which were unknown to her at the time of filing the SSS claim, she may still be able to file a civil action for damages under the Civil Code. Whether such supervening facts exist is a factual matter that must be determined.
The right to pursue a civil damages claim against CCC depends on whether Angel was aware of CCC's negligence or other relevant facts at the time she filed her SSS claim. If she was not aware and only discovered such facts later, she may still file a civil action. If no such supervening facts exist, her acceptance of SSS death benefits precludes her from seeking additional damages from CCC in court.
- citation lookup failed (3 provisions numbered 179 — name the Article/Title/Rule to disambiguate); used search
"Unless otherwise provided, the liability of the State Insurance Fund under this Title shall be exclusive and in place of all other liabilities of the employer to the employee, his dependents or anyone otherwise entitled to receive damages on behalf of the employee or his dependents."
"The rights and remedies granted by this Act to an employee by reason of a personal injury entitling him to compensation shall exclude all other rights and remedies accruing to the employee, his personal representatives, dependents or nearest of kin against the employer under the Civil Code and other laws, because of said injury."
Laws retrieved
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- Article 179, Labor Standards
- Section 2, Issuances of the Department of Labor and Employment and its Attached Agencies
- Article 178, Labor Standards
- Article 180, Labor Standards
- Section 3, Issuances of the Department of Labor and Employment and its Attached Agencies
- Article 2176, Obligations and Contracts and Related Laws
- Article 2177, Obligations and Contracts and Related Laws
- Article 2196, Obligations and Contracts and Related Laws
"Next, petitioner argues that private respondent had previously availed of the death benefits provided under the Labor Code and is, therefore, precluded from claiming from the deceased's employer damages under the Civil Code. ... Article 173 of the Labor Code states: Article 173. Extent of liability. - Unless otherwise provided, the liability of the State Insurance Fund under this Title shall be exclusive and in place of all other liabilities of the employer to the employee, his dependents or anyone otherwise entitled to receive damages on behalf of the employee or his dependents. WE now come to the query as to w…
"At issue is the exclusory provision of Section 5 of the Workmen's Compensation Act reiterated in Article 173 of the Labor Code 7 Sec. 5 _Exclusive right to compensation._ - The rights and remedies granted by this Act to an employee by reason of a personal injury entitling him to compensation shall exclude all other rights and remedies accruing to the employee, his personal representatives, dependents or nearest of kin against the employer under the Civil Code and other laws, because of said injury, Art. 173 _Exclusive of liability._ - Unless other wise provided, the liability of the State Insurance Fund under th…
The Supreme Court explained that claimants may invoke either the Workmen's Compensation Act or the provisions of the Civil Code, subject to the consequence that the choice of one remedy will exclude the other and that the acceptance of compensation under the remedy chosen will preclude a claim for additional benefits under the other remedy. The exception is where a claimant who has already been paid under the Workmen's Compensation Act may still sue for damages under the Civil Code on the basis of supervening facts or developments occurring after he opted for the first remedy. (D. M. Consunji v. Court Of Appeals, G.R. No. 137873)
A third view is that the action is selective and the employee or his heirs have a choice of availing themselves of the benefits under the WCA or of suing in the regular courts under the Civil Code for higher damages from the employer by reason of his negligence. But once the election has been exercised, the employee or his heirs are no longer free to opt for the other remedy. In other words, the employee cannot pursue both actions simultaneously. (30 v. Avelino, G.R. No. L-43674)
Cases retrieved
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