Cariaga vs LTBCo and MRR

GR No. L-11037, Dec 29, 1960

Syllabus: Cariaga, a medical student, was on board the LTB bus bound for Laguna when, upon reaching
the train crossing, it bumped the engine of the moving train of the MRR. He was hospitalized for his
serious injuries which reduced his intelligence and made him incapable of finishing his studies. He sued
the LTB and MRR for actual, compensatory, exemplary, and moral damages and attorney’s fees. The trial
court held LTB liable for compensatory damages. The Supreme Court held that the MRR was not guilty
of contributory negligence and that its driver made many warnings upon the crossing. The SC increased
the award of compensatory damages, taking into account the income he should have earned had he been
able to finish his studies and pass the boards (which is now impossible because of his injuries). Moral
damages, compensatory damages, and attorney’s fees weren’t granted, however, since the cause of action
did not arise out of a quasi-delict resulting to physical injuries.

Doctrine:

Damages recoverable from common carriers; Actual or compensatory

An obligor guilty of a breach of contract in good faith is liable under Art. 2201, NCC for such damages
which are the “natural and probable consequences of the breach and which the parties had foreseen at the
time the obligation was constituted,” provided such damages, according to Art. 2199 of the same Code,
have been duly proved. This would be the premise for the award of actual damages.