- Statute
- Revised Penal Code
- Article
- Art. 103
- Topic
- Statutory provision
- Status
- In force
- Year
- 1930
- Cited by
- Multiple Supreme Court decisions
The provision
Art. 103. Subsidiary civil liability of other persons. — The subsidiary liability established in the next preceding article shall also apply to employers, teachers, persons, and corporations engaged in any kind of industry for felonies committed by their servants, pupils, workmen, apprentices, or employees in the discharge of their duties.
Intellegal Wiki · In plain terms
The subsidiary civil liability set by the preceding article also falls on employers, teachers, and businesses or corporations in any industry for crimes committed by their servants, students, workers, apprentices, or employees while carrying out their assigned duties. If the offender cannot pay, the employer or institution answers for the civil liability.
An editorially maintained plain-language explanation of this provision — not legal advice.
Intellegal Wiki · How the courts apply it
In L.G. Foods Corporation v. Hon. Philadelfa B. Pagapong-Agraviador, the Supreme Court held: Denied the petition, holding that the complaint stated a quasi-delict cause of action under Civil Code Articles 2176 and 2180, for which employer liability is direct and immediate and not conditioned on a prior criminal conviction or the employee's insolvency, rather than subsidiary liability under Article 103 of the Revised Penal Code.
One leading Supreme Court case applying this provision.
Cases applying this article
- Calang v. People G.R. No. 190696
- L.G. Foods Corporation v. Hon. Philadelfa B. Pagapong-Agraviador G.R. No. 158995
- Bernardo Jocson v. Redencion Glorioso G.R. No. L-22686