International Flavors v. Merlin J. Argos

Summary

Former employees of IFFI filed civil damages case against the company for alleged defamation by their managing director Costa, claiming subsidiary liability. The Supreme Court ruled that such civil action is premature while criminal libel cases against the employee are pending. The Court distinguished between primary liability under Article 33 of the Civil Code (which allows independent civil action) and subsidiary liability under the Revised Penal Code (which requires prior conviction). Since respondents' complaint clearly sued IFFI in subsidiary capacity as employer, not primary capacity, the action was dismissed. The decision clarifies that subsidiary civil liability of employers arises only after employee's conviction in criminal cases, making any prior civil action premature.