- Petitioner
- Oceanmarine Resources Corporation
- Respondent
- Jenny Rose G. Nedic
- Citation
- G.R. No. 236263
- Court
- Supreme Court En Banc
- Division
- En Banc
- Ponente
- Zalameda, J.
- Decided
- July 19, 2022
Summary
This Supreme Court En Banc decision addresses the relationship between Civil Code Article 1711 and Labor Code compensation provisions when an employee dies during work. Romeo Ellao, a company driver, was killed by robbers while performing banking duties for his employer. His common-law partner sought damages for loss of earning capacity under Civil Code Article 1711. The RTC dismissed for lack of employer negligence, but the CA awarded damages citing automatic liability. The Supreme Court partially granted the employer's petition, clarifying that while the Labor Code's Title II superseded Article 1711, injured workers' heirs retain the choice between Labor Code compensation claims or Civil Code damage actions. The Court provided comprehensive historical analysis of Philippine compensation laws from 1927 to present, establishing that this choice-of-remedy doctrine allows alternative but not cumulative recovery, with acceptance of one remedy generally precluding the other.