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	GR No. 131280 2000-10-18	PEPE CATACUTAN and AURELIANA CATACUTAN v. HEIRS OF NORMAN KADUSALE YNARES-SANTIAGO, J.
only in the way of giving them benefit of counsel; and consequently doing away with the practice of leaving them to their fates. If these be done, the American rule requiring notice on the part of the employer shall have been satisfied (Miranda vs. Malate Garage and Taxicab, Inc., 99 Phil. 670, 675, citing Martinez vs. Barredo, supra)." More recently, in the case of Basilio v. Court of Appeals,[11] the issuance of a subsidiary writ of execution against the employer of the accused therein was once more upheld, notwithstanding the non-participation of such employer