Maria Agdoro v. Philippine Mining Industrial Co.; Vicenta Risari Vs. Philippine Mining Industrial Co.; Cesarea Concepcion

Summary

Three consolidated negligence cases where relatives of deceased workers sued Philippine Mining Industrial Co. for damages following a boat capsizing incident on June 20, 1919. The workers died when their banca capsized in heavy seas while being transported to the company's mining site on Calambayoñgan Island. The trial court found no negligence by the defendant company or its employees and dismissed all complaints. The Supreme Court affirmed, noting that since transportation was not part of the employment contract and the Employer's Liability Act notice requirements were not met, recovery could only be under Civil Code negligence provisions. With only partial evidence available on appeal, the Court could not disturb the trial court's factual finding of no negligence. The case establishes the requirement for clear proof of negligence in workplace accident claims under quasi-delict provisions of the Civil Code.