Benito Arambulo v. Manila Electric Company

Summary

This case establishes the doctrine of subsidiary civil liability under the Penal Code for employers whose employees commit crimes during work. Benito Arambulo sued Manila Electric Company after its motorman negligently killed his mother in a street car accident. The motorman was criminally convicted, but could not pay the civil indemnity. The Supreme Court held that employers cannot escape subsidiary liability by proving diligence in employee selection (unlike Civil Code provisions), and that subsidiary liability cannot exceed the principal's obligation. The Court modified the lower court's award, limiting Manila Electric's liability to P1,000 indemnity (matching the criminal judgment) rather than the original P1,300 awarded. This decision clarifies that subsidiary civil liability under criminal law operates independently from civil negligence principles and is governed by Penal Code provisions rather than Civil Code standards.