1. Vergara vs.

Court of Appeals

A court holds Vicente Vergara liable for damages caused by a vehicular accident, ruling
that he was negligent in the selection and supervision of his driver, resulting in a blown-
out tire and the steering wheel's failure to respond.

Facts:
The case of Vergara v. Court of Appeals involves an action for damages based on quasi-
delict filed by Amadeo Azarcon against Vicente Vergara. The incident occurred on
August 5, 1979, in Gapan, Nueva Ecija, when Martin Belmonte, while driving a cargo
truck owned by Vergara, crashed into Azarcon's store-residence, causing damages
amounting to P53,024.22.
Issue:
The main issue raised in the case is whether Vicente Vergara can be held liable for the
damages caused by the accident involving his cargo truck.
Ruling:
The Supreme Court denied the petition for review on certiorari filed by Vicente Vergara
and affirmed the decision of the Court of Appeals. The court upheld the award of
damages and attorney's fees to Amadeo Azarcon.
Ratio:
The court found that the requisites of a quasi-delict were present in the case. These
requisites are damages to the plaintiff, negligence by the defendant or someone for whom
he is responsible, and the connection between the negligence and the damages.
The court determined that Amadeo Azarcon indeed suffered damages as a result of
Vicente Vergara's act or omission. The court upheld the lower court's finding of
negligence based on the police report and testimony of Patrolman Masiclat. The report
stated that the cargo truck crossed to the wrong side of the road, causing a series of
collisions before crashing into Azarcon's store.
Vergara's defense that the accident was an act of God due to a blown-out tire was rejected
by the court. The court stated that the defects in the truck's brakes were curable and the
accident could have been prevented. Vergara failed to provide evidence to overcome the
presumption of negligence in the selection and supervision of his driver.
Therefore, the court upheld the award of damages and attorney's fees to Azarcon. The
petition for review was denied, and the decision of the Court of Appeals was affirmed.

Atty: the proximate cause is the negligence of the driver wa gi check ang truck before
gamiton

Dili ni sila fortuitous, kay ug gi check pa, di na unta maka aksidenti

2. People vs Sarion
Facts:
The case of Sarion v. People involves the conviction of former mayor Tito S. Sarion for
Malversation of Public Funds and violating Section 3 (e) of Republic Act No. 3019.
Sarion was the then Mayor of the Municipality of Daet. He was found guilty of
malversation through gross inexcusable negligence for approving the disbursement
voucher and signing the Landbank check for payment to Markbilt Construction, despite
the absence of appropriation and failure to comply with the requirements of the
Government Procurement Reform Act. Sarion was also convicted of violating Section 3
(e) of R.A. No. 3019 for gross inexcusable negligence in the disbursement of public
funds, causing undue injury to the Municipality of Daet.

What were the requirements?

No contract involving the expenditure of public funds shall be entered into unless there is
an appropriation therefor, the unexpended balance of which, free of other obligations, is
sufficient to cover the proposed expenditure.

Certificate showing appropriation to meet contract.

The certificate, signed by the proper accounting official and the auditor who verified it,
shall be attached to and become an integral part of the proposed contract,

The petitioner cannot rely on the doctrine in Arias v. Sandiganbayan to exculpate himself
from liability. As the Court stated in its Decision,
"the Arias doctrine is not a magic cloak that can be used as a cover by a public officer to
conceal himself in the shadows of his subordinates and necessarily escape liability."
When there are circumstances that should have alerted heads of offices to exercise a
higher degree of circumspection in the performance of their duties, they cannot invoke
the doctrine to escape liability. In this scenario, heads of offices are expected to exercise
more diligence and go beyond what their subordinates have prepared.

What were the circumstances that should have alerted him?

prudence dictates that further verification be conducted as to the veracity of the amount
claimed by Markbilt. The amount involved is by no means trivial; it involves millions of
pesos of public funds. Petitioner, as head of office, should have taken this precaution in
order to safeguard the government funds for which he is responsible and protect the
interests of the municipality.

Issue:
The main issue raised in the case is whether Sarion is guilty of malversation of public
funds and violating Section 3 (e) of R.A. No. 3019.
Ruling:
The Court affirmed the decision of the Sandiganbayan, which convicted Sarion of the
charges. Sarion's Motion for Reconsideration was denied.
Ratio:
The Court found that Sarion, as the then Mayor of the Municipality of Daet, was an
accountable officer of public funds and had the responsibility to ensure that these funds
are disbursed only for their intended municipal use. Sarion was found guilty of
malversation through gross inexcusable negligence for approving the disbursement
voucher and signing the Landbank check for payment to Markbilt Construction, despite
the absence of appropriation and failure to comply with the requirements of the
Government Procurement Reform Act. The Court ruled that Sarion cannot claim good
faith as a defense, as there were circumstances that should have alerted him to inquire
further before approving the payment.

Sarion was also convicted of violating Section 3 (e) of R.A. No. 3019 for gross
inexcusable negligence in the disbursement of public funds, causing undue injury to the
Municipality of Daet. The Court affirmed this conviction, stating that Sarion failed to
exercise diligence in ensuring compliance with the basic requirements of the law in the
disbursement of public funds.

In conclusion, the Court denied Sarion's Motion for Reconsideration and affirmed his
conviction for Malversation of Public Funds and violating Section 3 (e) of R.A. No.
3019. The Court found that Sarion committed gross inexcusable negligence in the
disbursement of public funds, causing undue injury to the Municipality of Daet.

Atty:

Good faith is not a defense. Naay omission mao na convict sija

Legal right

3. Elcano vs. Hilll

The case involves a civil action for damages filed by the parents of a deceased child
against a minor and his father, where the court ruled that the minor's acquittal in the
criminal case does not bar the civil action, and that the father is still liable despite the
minor's emancipation by marriage.
Facts:
The case of Elcano v. Hill was decided by the Supreme Court of the Philippines on May
26, 1977. The case involved a civil action for damages brought by the parents of a
deceased child against a minor and his father. The events leading to the case began when
the minor, who was driving a motorcycle, collided with the child, resulting in the child's
death. The parents of the deceased child filed a criminal case against the minor for
reckless imprudence resulting in homicide. However, the minor was acquitted in the
criminal case.
Issue:
The main issue raised in the case was whether the minor's acquittal in the criminal case
barred the parents from filing a civil action for damages against him. Additionally, the
court had to determine whether the minor's father could still be held liable for the
damages, despite the minor's emancipation by marriage.
Ruling:
The Supreme Court ruled in favor of the parents and held that the minor's acquittal in the
criminal case did not prevent them from pursuing a civil action for damages. The court
explained that the acquittal in the criminal case was based on the higher standard of proof
beyond reasonable doubt, while the civil action only required a preponderance of
evidence. Therefore, the minor's acquittal in the criminal case did not preclude the
parents from seeking civil damages.
Furthermore, the court held that the minor's father could still be held liable for the
damages, despite the minor's emancipation by marriage. The court reasoned that the
father, as the head of the family, had the legal duty to exercise parental authority and
control over his minor child. The minor's emancipation by marriage did not absolve the
father of this duty, and he could still be held responsible for the actions of his minor
child.
Ratio:
The Supreme Court based its decision on the distinction between the standards of proof in
criminal and civil cases. The court explained that the minor's acquittal in the criminal
case was based on the higher standard of proof beyond reasonable doubt, which is
required to establish guilt in a criminal case. On the other hand, a civil action for damages
only requires a preponderance of evidence, which means that the evidence presented
must be more convincing than the evidence presented by the other party. Therefore, the
minor's acquittal in the criminal case did not preclude the parents from seeking civil
damages.
Additionally, the court emphasized the continuing responsibility of parents for the actions
of their minor children. The court held that the minor's father, despite the minor's
emancipation by marriage, still had the legal duty to exercise parental authority and
control over his minor child. This duty extended to being held liable for the damages
caused by the minor's actions.
In conclusion, the Supreme Court ruled that the minor's acquittal in the criminal case did
not bar the parents from filing a civil action for damages, and that the minor's father
could still be held liable for the damages, despite the minor's emancipation by marriage.
The court highlighted the distinction between the standards of proof in criminal and civil
cases, and the continuing responsibility of parents for the actions of their minor children.

Atty: Rule 111 sec page 3 sa luansing

Basta di mo recover ka duha

4. Air France vs. Court of Appeals

Air France v. Court of Appeals is a case where Air France successfully appealed a ruling
that found them in breach of contract and awarded damages to a passenger, as the
Supreme Court determined that the airline had not violated the terms of the ticket and the
passenger failed to provide sufficient evidence of damages.

Facts:
The case of Air France v. Court of Appeals involves Narciso O. Morales, the private
respondent, who purchased an airline ticket from Aspac Management Corporation, Air
France's General Sales Agent in Makati, for P9,426.00 plus P413.90 travel tax. The ticket
included several cities in its itinerary, with certain segments restricted by markings of
"non-endorsable" and "valid on Air France only". While in New York, Morales obtained
medical certificates for an ear infection and requested to shorten his trip by deleting some
cities in the itinerary. Air France informed him that confirmation from their office in
Manila was required before making any changes. Despite repeated requests and the
presentation of medical certificates, Air France denied Morales' request to reroute his trip.
Morales then had to buy a new set of tickets to return to Manila. He filed a complaint for
breach of contract of carriage and damages against Air France.
Issue:
The main issues raised in the case are: 1) Whether there was a breach of contract of
carriage on the part of Air France, and 2) Whether the award of damages is proper.
Ruling:
The Supreme Court ruled in favor of Air France. They found that there was no breach of
contract as the original ticket had restrictions that prohibited rerouting. They also noted
that Morales, being a lawyer, should have been aware of these restrictions. The Court
emphasized that mere refusal to accede to a passenger's wishes does not necessarily
translate into damages in the absence of bad faith. They also found that Morales failed to
provide sufficient evidence of the factual basis of the damages and its causal connection
to Air France's actions. Therefore, the Court reversed the decision of the Court of
Appeals and ordered Air France to refund the value of the unused coupons in Morales'
ticket.

5. Banzon vs. Court of Appeals

Background of the Case
• Maximo R. Sta. Maria obtained crop loans from the Philippine National Bank
(PNB).
• Associated Insurance and Surety, Inc. acted as surety for Sta. Maria by filing
surety bonds to guarantee the repayment of the loans.
• Antonio R. Banzon and Emilio R. Naval acted as indemnitors of Associated.
• Sta. Maria failed to pay his loan obligations to PNB.
• Instead of paying the bank, Associated filed a complaint against Sta. Maria,
Banzon, and Naval, claiming the outstanding obligation of Sta. Maria amounted to a
certain amount.
• The properties of Banzon covered by TCT Nos. 39685 and 53759 were levied and
sold in execution.
• The properties were eventually bought by the Cardenas spouses to satisfy a
judgment debt of Associated.
Issue:
The main issue in the case is whether or not the Sta. Marias are liable for the prejudice
and damages suffered by Banzon and Balmaceda.
Ruling:
The Court affirms the decision of the Court of Appeals, absolving the defendants from
any liability.
Ratio:
The Court attributes the wrongful taking of Banzon's properties to the premature acts of
Associated Insurance and Surety, Inc., rather than the defendants' failure to pay their
obligations. The Court emphasizes that moral damages may only be recovered if they are
the proximate result of the defendant's wrongful act or omission. In this case, the Court
concludes that the prejudice suffered by Banzon is not the natural and probable
consequence of the defendants' failure to pay their crop loans. It was the premature and
fraudulent acts of Associated that directly caused the harm. Therefore, the Court holds
that the defendants are not liable for the damages suffered by Banzon and Balmaceda.

Cinco vs Canonoy

Petitioner filed a complaint in the City Court for recovery of damages on account of a
vehicular accident involving his car and a jeepney driven by respondent Romeo Hilot and
operated by respondents Valeriana Pepito and Carlos Pepito. Subsequently, a criminal
case was filed against the driver. At the pre-trial of the civil case counsel for the
respondents moved for the suspension of the civil action pending determination of the
criminal case invoking Section 3(b), Rule 111 of the Rules of Court. The City Court
granted the motion and ordered the suspension of the civil case. Petitioner elevated the
matter on certiorari to the Court of First Instance, alleging that the City Judge acted with
grave abuse of discretion in suspending the civil action for being contrary to law and
jurisprudence. The Court of First Instance dismissed the petition; hence, this petition to
review on certiorari.

Issue:

The issue to be resolved is whether or not there can be an independent civil action for
damages to property during the pendency of the criminal action.

Ruling:

The Supreme Court held that an action for damages based on Articles 2176 and 2180 of
the New Civil Code is quasi-delictual in character which can be prosecuted independently
of the criminal action.
Petition granted.

Cayao-Lasam vs. Spouses Ramolete

A doctor fights to annul the revocation of her medical license after being accused of
negligence and malpractice in a case involving a patient who suffered a ruptured uterus,
but the Supreme Court rules in her favor due to insufficient evidence and violation of her
right to due process.

Case Digest
Facts:
The case involves Dr. Fe Cayao-Lasam, a doctor who is seeking to annul the revocation
of her medical license. The events of the case took place in San Fernando, La Union,
Philippines. On July 28, 1994, Editha Ramolete, who was three months pregnant, was
brought to the Lorma Medical Center (LMC) due to vaginal bleeding. Dr. Cayao-Lasam
advised Editha to undergo a Dilatation and Curettage Procedure (D&C) or "raspa" due to
persistent and profuse vaginal bleeding. The D&C procedure was performed on July 30,
1994, and Editha was discharged from the hospital the following day. On September 16,
1994, Editha was brought back to the LMC due to vomiting and severe abdominal pains.
She was found to have a massive intra-abdominal hemorrhage and a ruptured uterus. As a
result, Editha had to undergo a hysterectomy and lost the chance to bear a child. Editha
and her husband filed a complaint for gross negligence and malpractice against Dr.
Cayao-Lasam before the Professional Regulations Commission (PRC), alleging that the
hysterectomy was caused by the petitioner's negligence and incompetence in conducting
the D&C procedure and her failure to remove the fetus inside Editha's womb. The Board
of Medicine of the PRC initially exonerated Dr. Cayao-Lasam, but on appeal, the PRC
reversed the decision and revoked her medical license.
Issue:
The main issue in this case is whether the revocation of Dr. Cayao-Lasam's medical
license by the PRC is valid and in accordance with due process.
Ruling:
The Supreme Court ruled in favor of Dr. Cayao-Lasam, reversing the decision of the
Court of Appeals (CA). The Court held that the PRC decision was null and void because
it violated Dr. Cayao-Lasam's right to due process. The Court also found that there was
insufficient evidence to prove negligence and malpractice on the part of Dr. Cayao-
Lasam. The Court emphasized that Editha's own omission in not returning for a follow-up
evaluation was the proximate cause of her injury, and not the D&C procedure conducted
by Dr. Cayao-Lasam.
Ratio:
The Supreme Court based its decision on the violation of Dr. Cayao-Lasam's right to due
process. The Court found that the PRC decision was issued without jurisdiction and
violated the petitioner's right to be heard and present evidence in her defense. The Court
emphasized that due process requires that a person be given the opportunity to be heard
and defend themselves before any adverse action is taken against them. In this case, the
PRC decision to revoke Dr. Cayao-Lasam's medical license was made without giving her
the opportunity to present her side and refute the allegations against her.
Furthermore, the Court found that there was insufficient evidence to prove negligence
and malpractice on the part of Dr. Cayao-Lasam. The Court noted that the Board of
Medicine of the PRC initially exonerated Dr. Cayao-Lasam, stating that the D&C
procedure was necessary considering Editha's condition and that the rupture of the uterus
was caused by an extremely rare case of ectopic pregnancy interstitial. The Court agreed
with the initial finding of the Board of Medicine and found that there was no evidence to
support the claim of negligence and malpractice.
The Court also emphasized that Editha's own omission in not returning for a follow-up
evaluation was the proximate cause of her injury. The Court noted that Editha failed to
follow the medical advice given to her by Dr. Cayao-Lasam, which included a
recommendation for a follow-up evaluation. The Court held that Editha's failure to seek
further medical attention contributed to her injury and cannot be solely attributed to the
D&C procedure conducted by Dr. Cayao-Lasam.
In conclusion, the Supreme Court ruled in favor of Dr. Cayao-Lasam, stating that there
was insufficient evidence to prove negligence and malpractice. The Court also found that
Editha's own omission in not returning for a follow-up evaluation was the proximate
cause of her injury. The PRC decision revoking Dr. Cayao-Lasam's medical license was
declared null and void.

8.Ramos vs CA GR

After undergoing a gall bladder operation, Erlinda Ramos suffered brain damage and fell
into a comatose state, leading to a civil case for damages against the hospital and doctors
involved; the Supreme Court ruled in favor of the plaintiffs, applying the doctrine of res
ipsa loquitur and ordering the defendants to pay damages.
Facts:
This case involves a medical malpractice claim filed by Rogelio and Erlinda Ramos
against the doctors and hospital involved in Erlinda's gall bladder operation. After the
operation, Erlinda suffered brain damage and fell into a comatose state. The trial court
ruled in favor of the plaintiffs, finding the defendants liable for negligence in the
performance of their professional duties. However, the Court of Appeals reversed the
decision, dismissing the complaint against the defendants.
Issue:
The main issue in this case is whether the doctors and hospital should be held liable for
the comatose condition of Erlinda Ramos.
Ruling:
The Supreme Court ruled in favor of the plaintiffs, applying the doctrine of res ipsa
loquitur. The court found that the defendants were negligent in the care and management
of Erlinda during the anesthesia phase of the operation. The court held that the faulty
intubation was the proximate cause of Erlinda's comatose condition. The court rejected
the defendants' argument that the brain damage was due to an allergic reaction to the
anesthetic drug, as there was no evidence to support this claim. The court also found that
the defendants failed to properly evaluate Erlinda's condition prior to the operation,
which was a clear indication of negligence.
Ratio:
The court based its ruling on the doctrine of res ipsa loquitur, which means "the thing
speaks for itself." This doctrine allows the court to infer negligence from the mere
occurrence of an accident or injury. In this case, the court found that the defendants'
negligence was evident from the fact that Erlinda suffered brain damage and fell into a
comatose state after the operation. The court held that the defendants had the duty to
exercise the highest degree of care and skill in the performance of their professional
duties, and their failure to do so constituted negligence.
The court also applied the principle of proximate cause in its ruling. Proximate cause
refers to the act or omission that directly produces an injury or damage. In this case, the
court found that the faulty intubation was the proximate cause of Erlinda's comatose
condition. The court reasoned that the defendants' negligence in the care and management
of Erlinda during the anesthesia phase of the operation triggered a chain of events that led
to her brain damage and comatose state.
Furthermore, the court held that the hospital was also liable for the acts of negligence of
the doctors in their practice of medicine in the operating room. The court rejected the
hospital's argument that it was not liable for the actions of its consultants, and held that an
employer-employee relationship exists between hospitals and their attending and visiting
physicians. Therefore, the hospital is solidarily liable with the doctors for Erlinda's
condition.
In terms of damages, the court awarded the plaintiffs various forms of compensation,
including actual monthly expenses, attorney's fees, moral damages, and exemplary
damages. The court considered the actual expenses incurred by the plaintiffs in caring for
Erlinda, as well as the emotional and psychological suffering they endured as a result of
her condition. The court also imposed exemplary damages to serve as a deterrent to
others and to punish the defendants for their negligence.
In summary, the Supreme Court ruled in favor of the plaintiffs, finding the defendants
liable for negligence in the care and management of Erlinda during the anesthesia phase
of the operation. The court applied the doctrine of res ipsa loquitur and the principle of
proximate cause in its ruling. The court also held the hospital solidarily liable with the
doctors. The court awarded the plaintiffs various damages, including actual, moral,
temperate, and exemplary damages, as well as attorney's fees.

9. LG Foods vs Philadelfa

The court rules that the cause of action of the parents of a child killed in a car accident is
not founded on the subsidiary liability of employers for the negligence of their
employees, but rather on the direct and immediate liability of the employers under Article
2180 of the Civil Code.

On February 26, 1996, Charles Vallejera, a 7-year old son of the spouses Florentino
Vallejera and Theresa Vallejera, was hit by a Ford Fiera van owned by the petitioners and
driven by their employee, Vincent Norman Yeneza. Charles died as a result of the
accident. An Information for Reckless Imprudence Resulting to Homicide was filed
against the driver, but before the trial could be concluded, the accused driver committed
suicide and the criminal case was dismissed.
On June 23, 1999, the spouses Vallejera filed a complaint for damages against the
petitioners as employers of the deceased driver, alleging that they failed to exercise due
diligence in the selection and supervision of their employees. The petitioners denied
liability and filed a motion to dismiss, arguing that the complaint is a claim for subsidiary
liability against an employer and that there must first be a judgment of conviction against
their driver as a condition to hold them liable. The trial court denied the motion to
dismiss, and the CA upheld the trial court's decision.

Issue:
The main issue in this case is whether the spouses Vallejera's cause of action is founded
on Article 103 of the Revised Penal Code (subsidiary liability of employers) or Article
2180 of the Civil Code (direct and immediate liability of employers).

Ruling:

Cause of Action is founded on Article 2180 of the Civil Code (direct and immediate
liability of employers).
Civil Case No. 99-10845 is a negligence suit brought under Article 2176 Civil Code to
recover damages primarily from the petitioners as employers responsible for their
negligent driver pursuant to Article 2180 of the Civil Code. The obligation imposed by
Article 2176 is demandable not only for one's own acts or omissions, but also for those of
persons for whom one is responsible. Thus, the employer is liable for damages caused by
his employees and household helpers acting within the scope of their assigned tasks, even
though the former is not engaged in any business or industry.

The circumstance that no reservation to institute a separate civil action for damages was
made when the criminal case was filed is of no moment for the simple reason that the
criminal case was dismissed without any pronouncement having been made therein. In
reality, therefor, it is as if there was no criminal case to speak of in the first place. And for
the petitioners to insist for the conviction of their driver as a condition sine qua non to
hold them liable for damages is to ask for the impossible.

Cagayan II Electric Cooperative, Inc. vs. Rapa

A petition for review on certiorari is filed against Cagayan II Electric Cooperative, Inc.
by Rapanan and Tangonan, claiming negligence resulting in death and injuries, but the
Supreme Court reverses the decision, finding no negligence on the part of the petitioner
and denying damages to the legal heirs.

Facts:

This case involves a petition for review on certiorari filed by Cagayan II Electric
Cooperative, Inc. (CAGELCO II) against respondents Allan Rapanan and Mary Gine
Tangonan. The case revolves around a motorcycle accident that resulted in the death of
Camilo Tangonan and injuries to Rapanan. The accident occurred when the motorcycle
they were riding on was struck and electrocuted by a live tension wire from one of
CAGELCO II's electric posts. Rapanan and Tangonan filed a complaint for damages
against CAGELCO II, alleging negligence in failing to fix and change the live tension
wire despite being informed of the danger it posed. They sought damages for the death of
Camilo, as well as Rapanan's injuries. The Regional Trial Court (RTC) dismissed the
complaint, ruling that the proximate cause of the accident was Camilo's negligence and
that Tangonan had no legal standing to file the complaint. On appeal, the Court of
Appeals (CA) reversed the RTC's decision and held CAGELCO II liable for quasi-delict.
The CA awarded damages to Rapanan and Camilo's legal heirs. CAGELCO II filed a
petition for review on certiorari with the Supreme Court.
Issue:
The main issues before the Supreme Court were: (1) whether CAGELCO II's negligence
was the proximate cause of the accident, and (2) whether damages should be awarded to
Camilo's legal heirs even if they were not impleaded in the case.
Ruling:
The Supreme Court ruled in favor of CAGELCO II. It found that there was no negligence
on the part of CAGELCO II that could be considered the proximate cause of the accident.
Testimonies from CAGELCO II's employees and the police blotter indicated that the live
tension wire was placed at the shoulder of the road, away from the concrete portion, to
ensure the safety of motorists and pedestrians. The Court concluded that the accident was
caused by Camilo's negligence and imprudence in driving the motorcycle at a high speed,
which resulted in the motorcycle tilting and sliding, throwing the passengers off towards
the shoulder where the live wire was located. The Court also noted that Camilo allowed
two passengers to ride with him, exceeding the maximum number of passengers allowed
on a motorcycle.
Regarding the second issue, the Court held that Camilo's common law wife, Tangonan,
had no legal standing to file the complaint on behalf of Camilo's legal heirs. As a mere
common law wife, she was not considered a legal heir and therefore had no legal
personality to institute the action for damages due to Camilo's death.

Ratio:
The Supreme Court based its decision on the evidence presented during the trial. It found
that CAGELCO II was not negligent in placing the live tension wire at the shoulder of the
road, as this was done to ensure the safety of motorists and pedestrians. The Court also
found that the accident was caused by Camilo's negligence and imprudence in driving the
motorcycle at a high speed and allowing two passengers to ride with him. These actions
were in violation of traffic rules and regulations.

Furthermore, the Court emphasized that Tangonan, as a mere common law wife, did not
have the legal standing to file the complaint on behalf of Camilo's legal heirs. Only the
legal heirs, who were not impleaded in the case, had the right to claim damages for
Camilo's death. Therefore, the Court reinstated the decision of the Regional Trial Court,
dismissing the complaint for damages filed by Rapanan and Tangonan against
CAGELCO II.

Proximate cause: ang motorcycle overspeeding

Negligence is defined here

Negligence sa Cagayan: undisputed kay naa may namatay pero held by the court that
Cagayan is not liable kay gipa daplin na ang wire, ug di pa tungod sa kakusog sa padagan
wa unta sija mamatay
Sa quasi delict tan awon jud ang proximate cause.

Sa death ra ni Camillo liable ang Cagayan mao mo dawat sa damage ijang anak dili ang
common law.

Ma-ao Sugar Central Co. vs. Barrios

Facts:
The case of Ma-ao Sugar Central Co. v. Barrios involves a sugar company, Ma-ao Sugar
Central Co., filing a motion to dismiss a complaint seeking payment of debts owed before
the war. The company argues that the debts were not yet payable due to a debt
moratorium. The lower court denied the motion to dismiss, prompting the company to
file a petition for certiorari and prohibition to set aside the order and to prevent the court
from taking cognizance of the case.

Issue:
The main issue raised in the case is whether or not the complaint filed by the respondents
states facts sufficient to constitute a cause of action.

The petitioner argues that the debts are not yet payable due to the debt moratorium
provided in Executive Order No. 25, as amended by Executive Order No. 32.

Ruling:
The court ruled in favor of the petitioner, stating that the complaint did not state a cause
of action. The court explains that a cause of action requires the violation of a legal right,
the correlative obligation of the defendant, and the act or omission of the defendant in
violation of said legal right. In this case, the complaint alleges the legal right of the
plaintiffs to be paid the amount due to them, as well as the correlative obligation of the
defendant to pay. However, the complaint does not allege the omission on the part of the
defendant to pay in violation of the legal rights of the plaintiffs. The court emphasizes
that the debt moratorium suspends the filing of suits for the enforcement of the payment
of debts and other monetary obligations. Therefore, the plaintiffs have no cause of action
against the defendant until after the termination of the moratorium.

"III. DEBT MORATORIUM

"1. Enforcement of payment of all debts and other monetary obligations payable within
the Philippines, except debts and other monetary obligations entered into in any area after
the declaration by Presidential Proclamation that such area has been freed from enemy
occupation and control, is temporarily suspended pending action by the Commonwealth
Government." (41 Off. Gaz., No. 1, p. 56.)
Atty: this DISCUSSES requisites sa cause of action

Legal right of the plaintiff

Obligation of the defendant
Act or omission of the defendant in violation of the said right

Di mo puydi suktan ug wapa ni duty

Custodio and Santos vs CA

Facts:
The case involves a dispute over the grant of a right of way and the award of damages.
The petitioners, Spouses Cristino and Brigida Custodio and Spouses Lito and Maria
Cristina Santos, filed a petition for review on certiorari assailing the decision of the Court
of Appeals. The Court of Appeals affirmed with modification the decision of the trial
court, which granted the right of way to the private respondents, Heirs of Pacifico C.
Mabasa, and awarded damages to them.
The facts of the case are as follows: Pacifico Mabasa filed a case for the grant of an
easement of right of way against the petitioners before the Regional Trial Court of Pasig.
Mabasa owned a parcel of land with a two-door apartment, which was surrounded by the
properties of the petitioners. There were two possible passageways for Mabasa's property
to have access to the public street. However, the petitioners constructed a fence in the
first passageway, making it narrower. This led to the remaining tenants vacating the
apartment. The trial court granted Mabasa the right of way and ordered the petitioners to
pay indemnity for the use of the passageway.
Issue:
The main issues raised in the case are: 1) whether the grant of right of way to the private
respondents is proper, and 2) whether the award of damages is justified.
Ruling:
The court ruled that the petitioners are already barred from raising the issue of the grant
of right of way because they did not appeal from the decision of the trial court. The
decision of the trial court has become final as against them, and they cannot obtain any
affirmative relief other than what was granted in the decision.

Regarding the award of damages, the court held that there was no legal injury to the
private respondents. The act of the petitioners in constructing a fence within their
property was a valid exercise of their right as owners and was not contrary to morals,
good customs, or public policy. The lot was not subject to any servitudes at the time of
the construction of the fence. Therefore, whatever injury or damage may have been
sustained by the private respondents was damnum absque injuria, or damage without
legal injury. The court emphasized that the proper exercise of a lawful right cannot
constitute a legal wrong for which an action will lie.

Ratio:
The court's decision is based on the principle that a party who fails to appeal from a
decision of the trial court is already barred from raising any issue that could have been
raised in the appeal. In this case, the petitioners did not appeal from the trial court's
decision granting the right of way to the private respondents. As a result, the decision has
become final as against them, and they cannot obtain any affirmative relief other than
what was granted in the decision.
Furthermore, the court found that the petitioners' act of constructing a fence within their
property was a valid exercise of their right as owners. There was no legal prohibition
against their actions, and they did not violate any moral, customary, or public policy
standards. The lot was not subject to any servitudes at the time of the construction of the
fence. Therefore, the injury or damage sustained by the private respondents was not
caused by any legal wrong committed by the petitioners. The court emphasized that the
proper exercise of a lawful right cannot be considered a legal wrong for which an action
will lie.
In conclusion, the court reversed the decision of the Court of Appeals and reinstated the
judgment of the trial court, which granted the right of way to the private respondents but
did not award damages to them.

Atty: bisag naay damge pero walay injury

damnum absque injuria, or damage without legal injury

def could have acted contrary moral

act wilful
naay damage sa plaintiff

way legal injury bisag naay damage.

Tan awon jud ug naa bay legal right ng ana harm.

Injury is defined vs Damage are discussed here. Take note sa difference

damnum absque injuria

- Dapat naa juy legal wrong para maka recover ug damages
- -while an act naka cause damage to another pero ang actor has no liability kay way
na violate nga legal right

Jovellnos et al vs CA et al
A dispute over the ownership of a property in Quezon City, Philippines leads to a ruling
in favor of Annette H. Jovellanos and her minor daughters, affirming that the property
belonged to the conjugal partnership of Daniel Jovellanos and Annette H. Jovellanos,
with reimbursements to be made for their proportionate shares in the expenses related to
the property.

Facts:
The case of Jovellanos v. Court of Appeals involves a dispute over the ownership of a
property in Quezon City, Philippines. The petitioners in this case are Wilhelmina
Jovellanos, Mercy Jovellanos-Martinez, and Jose Hermilo Jovellanos, while the
respondents are Annette H. Jovellanos and her two minor daughters. The case was
decided on June 18, 1992, by the Second Division of the Supreme Court of the
Philippines, with Justice Regalado as the ponente.
In 1955, Daniel Jovellanos entered into a lease and conditional sale agreement with
Philippine American Life Insurance Company (Philamlife) for a property in Quezon City.
At that time, Daniel Jovellanos was married to his first wife, Leonor Dizon, with whom
he had three children (the petitioners). Leonor Dizon passed away in 1959, and in 1967,
Daniel Jovellanos married Annette H. Jovellanos, with whom he had two children (the
respondents). In 1971, one of the petitioners, Mercy Jovellanos, married Gil Martinez and
they built a house on the property. In 1975, after full payment of the rentals, Philamlife
executed a deed of absolute sale in favor of Daniel Jovellanos. Daniel Jovellanos then
donated his rights, title, and interests over the property to the petitioners. Daniel
Jovellanos passed away in 1985, leading to the filing of the present case.
Issue:
The main issue in this case is the ownership of the property. The petitioners argue that the
property was acquired during the first marriage under the lease and conditional sale
agreement, while the respondents claim that it was acquired during the second marriage
through the deed of absolute sale.
Ruling:
The ruling of the court is in favor of the respondents. The court held that the lease and
conditional sale agreement is in the nature of a contract to sell, where ownership is
transferred upon full payment of the purchase price. The court also found that the
property belonged to the conjugal partnership of Daniel Jovellanos and Annette H.
Jovellanos, as it was acquired during their marriage. The court applied Article 118 of the
Family Code, which provides that property bought on installment paid partly from
exclusive funds of either or both spouses and partly from conjugal funds belongs to the
buyer or buyers if full ownership was vested before the marriage and to the conjugal
partnership if such ownership was vested during the marriage. The court ordered the
liquidation of the partnership and the reimbursement of the amount advanced by the
partnership and the petitioners in the acquisition of the property.
Ratio:
The ratio of the case is that the lease and conditional sale agreement is a contract to sell,
where ownership is transferred upon full payment of the purchase price. The property in
question belonged to the conjugal partnership of Daniel Jovellanos and Annette H.
Jovellanos, as it was acquired during their marriage. The court applied Article 118 of the
Family Code, which provides for the reimbursement of amounts advanced by the
partnership or by either or both spouses upon liquidation of the partnership. The court
also emphasized that the Family Code has retroactive effect, as long as it does not
prejudice or impair vested or acquired rights in accordance with the Civil Code or other
laws.

Escano vs. Court of Appeals

In the case of Escano v. Court of Appeals, the Court held that the Court of Appeals erred
in imposing conditions on the repurchase of the lots that were not raised in the pleadings,
and also erred in denying the petitioners' claim for compensation for the use of the lots by
the CAA

Facts:
In the case of Escano v. Court of Appeals, the facts are as follows: In 1964, ten lots with
a total area of 10,639 square meters were sold by Mamerto Escao, Inc. to the Republic of
the Philippines for use by the Civil Aeronautics Administration (CAA) as part of the
Lahug Airport in Cebu City. The sale was subject to the condition that when the CAA
would no longer use the lots as part of the airport, the title would revert to the seller upon
reimbursement of the price without interest. In 1966, the petitioners became the
successors of Mamerto Escao, Inc. to the right to repurchase the lots from the Republic of
the Philippines. The Mactan Airport commenced its operation in 1966, and the Lahug
Airport ceased to be used by the Philippine Airlines and other airlines.

On October 2, 1972, the petitioners tendered the repurchase price to the CAA, claiming
that the condition for repurchase had been fulfilled. However, the Director of Civil
Aviation rejected the tender, stating that the lots could not yet be released and returned to
the reversionary owners because the Lahug Airport was still being utilized for general
aviation. The petitioners then filed a lawsuit in the Court of First Instance of Cebu for the
reconveyance of the lots. The trial court ruled in favor of the petitioners, ordering the
CAA to reconvey the lots after payment of the repurchase price. However, the trial court
did not award compensation for the use and occupation of the lots by the CAA.
Issue:
The main issue raised in the case is whether the Court of Appeals erred in imposing
conditions on the reconveyance of the lots that were not raised in the pleadings, and in
denying the petitioners' claim for compensation for the use of the lots by the CAA.
Ruling:
The Supreme Court held that the Court of Appeals erred in imposing the conditions on
the reconveyance of the lots. The conditions were not raised in the pleadings and were
not included in any assignment of errors in the Government's brief. The Court of Appeals
also disregarded the rule that only errors that affect the jurisdiction over the subject
matter will be considered on appeal unless stated in the assignment of errors and properly
argued in the brief.

The Court held that the 1964 contract of sale between the petitioners' predecessors-in-
interest and the Government is the law between them, and the fact that the contract does
not mention the conditions means that they were never within the contemplation of the
parties. The Court also found that one of the conditions nullifies the reversionary
condition and contradicts the trial court's findings that the Lahug Airport had ceased to be
operational.
Regarding the claim for compensation, the Court held that while the claim may be
justified, it would be inequitable to require the CAA to pay compensation when it had not
derived any benefit from the lots. The Court also noted that the petitioners had been able
to use the redemption price for their own purposes during the delay in the reconveyance.
The Court concluded that if any damage had been suffered by the petitioners, it might be
equivalent to damage without injury or loss without violation of a legal right, for which
the law provides no remedy. Therefore, the Court affirmed the trial court's judgment but
modified the decision of the Court of Appeals by deleting the conditions for the
reconveyance of the lots.

Atty: damage w/o injury

if any damage had been suffered by the petitioners, it might be equivalent to damage
without injury or loss without violation of a legal right, for which the law provides no
remedy.
No legal wrong kay wa sila nabalikan sa ilang lot pero way right ng ana violate

Ratio:
The Court's decision was based on the following arguments and legal basis:
1. The Court of Appeals erred in imposing conditions on the reconveyance of the lots
that were not raised in the pleadings. The conditions were not included in any assignment
of errors in the Government's brief and were not within the contemplation of the parties
as they were not mentioned in the 1964 contract of sale. The Court held that the contract
is the law between the parties and the absence of the conditions in the contract means that
they were never agreed upon.
2. The Court of Appeals disregarded the rule that only errors that affect the
jurisdiction over the subject matter will be considered on appeal unless stated in the
assignment of errors and properly argued in the brief. The Court emphasized that the
conditions imposed by the Court of Appeals were not properly raised and argued in the
lower court.
3. One of the conditions imposed by the Court of Appeals nullifies the reversionary
condition stated in the contract and contradicts the trial court's findings that the Lahug
Airport had ceased to be operational. The Court found that this condition is inconsistent
with the facts of the case and should not have been imposed.
4. While the claim for compensation for the use of the lots may be justified, the
Court held that it would be inequitable to require the CAA to pay compensation when it
had not derived any benefit from the lots. The Court also considered that the petitioners
had been able to use the redemption price for their own purposes during the delay in the
reconveyance. The Court concluded that if any damage had been suffered by the
petitioners, it might be equivalent to damage without injury or loss without violation of a
legal right, for which the law provides no remedy.
Based on these arguments and legal basis, the Court affirmed the trial court's judgment
but modified the decision of the Court of Appeals by deleting the conditions for the
reconveyance of the lots.

Ilocos Norte Electric Co. vs. Court of Appeals

The court holds the electric company liable for the death of a woman who was
electrocuted during a typhoon, emphasizing the duty of electric companies to ensure
public safety, and awards damages to the respondents.

Facts:
The case of Ilocos Norte Electric Co. v. Court of Appeals involves the death of Isabel
Lao Juan, who was electrocuted during a typhoon. On the evening of June 28 until the
early morning of June 29, 1967, a strong typhoon named "Gening" hit the province of
Ilocos Norte, causing heavy rains and flooding. Isabel Lao Juan ventured out of her son-
in-law's house to check on her store, which may have been damaged by the flood. She
was followed by two witnesses, Aida Bulong and Linda Alonzo Estavillo. While wading
through waist-deep floodwaters, Isabel suddenly screamed and sank into the water. The
witnesses saw an electric wire dangling from a post and moving in a snake-like fashion in
the water. They tried to help but were afraid to approach due to the presence of the live
wire. Ernesto dela Cruz, who came out of the house, also attempted to help but turned
back when he realized the water was grounded. Isabel's son-in-law, Antonio Yabes, was
informed of the incident and immediately sought help from the police and the electric
company to cut off the electric current. The body of Isabel was later recovered near an
electric post.

Issue:
The main issues raised in the case are: (1) whether Isabel died of electrocution, (2)
whether the petitioner, Ilocos Norte Electric Company, can be held liable for the death,
and (3) whether the Court of Appeals' reversal of the trial court's findings of fact was
proper.
Ruling:
The court ruled in favor of the respondents on all three issues. It found that Isabel died of
electrocution based on the testimony of witnesses and the presence of burnt wounds on
her left palm. The court also held the petitioner liable for the death, as it failed to exercise
the necessary diligence to prevent harm to the public during the typhoon. The court
rejected the petitioner's argument that the death was solely due to a fortuitous event, as it
was through the petitioner's negligence that the death occurred. Finally, the court
affirmed the Court of Appeals' reversal of the trial court's findings of fact, as it found that
the trial court's findings were based on what the petitioner's employees were supposed to
do, rather than what they actually did during the typhoon.
Ratio:
The court's decision was based on the duty of electric companies to ensure public safety.
The court emphasized that electric companies have the responsibility to exercise the
necessary diligence to prevent harm to the public, especially during natural disasters such
as typhoons. In this case, the court found that the petitioner failed to fulfill this duty, as it
did not take appropriate measures to prevent the live wire from endangering the public.
The court also considered the testimony of witnesses and the presence of burnt wounds
on Isabel's left palm as evidence of electrocution.
The court rejected the petitioner's argument that the death was solely due to a fortuitous
event. It held that the petitioner's negligence in failing to secure the live wire was the
proximate cause of Isabel's death. The court emphasized that even in the face of a
typhoon, the petitioner should have taken reasonable steps to ensure the safety of the
public.
Regarding the reversal of the trial court's findings of fact, the court agreed with the Court
of Appeals' decision. It found that the trial court's findings were based on what the
petitioner's employees were supposed to do, rather than what they actually did during the
typhoon. The court considered the actual actions and negligence of the petitioner's
employees in determining liability.
In terms of damages, the Court of Appeals awarded the respondents actual damages of
P30,229.45, compensatory damages of P50,000, exemplary damages of P10,000,
attorney's fees of P3,000, and costs of suit. The Supreme Court affirmed the award of
damages and attorney's fees, but increased the compensation for the victim's death from
P12,000 to P30,000, resulting in a total actual damages of P48,229.45. The court
excluded moral damages and attorney's fees awarded by the trial court, as there was no
evidence of malice or bad faith on the part of the respondents in filing the case.

Atty: sakto nga ang bagjo acs of Gods, pero ang negligence companya maoy naka
among sa namatay wa nag exercise of extra ordinary negligence being a public
utility.

Gi bas ani atty.

For it has been held that a person is excused from the force of the rule, that when he
voluntarily assents to a known danger he must abide by the consequences, if an
emergency is found to exist or if the life or property of another is in peril (65A C.S.C.
Negligence (174(5), p. 301), or when he seeks to rescue his endangered property (Harper
and James, "The Law of Torts." Little, Brown and Co., 1956, v. 2, p. 1167). Clearly, an
emergency was at hand as the deceased's property, a source of her livelihood, was faced
with an impending loss.

In times of calamities such as the one which occurred in Laoag City on the might of June
28 until the early hours of June 29, 1967, extraordinary diligence requires a supplier
of electricity to be in constant vigil to prevent or avoid any probable incident that might
imperil life or limb. The evidence does not show that defendant did that. On the
contrary, evidence discloses that there were no men (linemen or otherwise) policing the
area, nor even manning its office.

Albenson Enterprises Corp. vs. Court of Appeals

1. Albenson Enterprises Corp. filed a criminal case against Eugenio S. Baltao for a
dishonored check.
2. The check was drawn against the account of E.L. Woodworks and was dishonored
for the reason "Account Closed."
3. Albenson traced the origin of the dishonored check and discovered that the
president of Guaranteed Industries, the recipient of the unpaid mild steel plates, was
Eugenio S. Baltao.
4. Albenson made an extrajudicial demand upon Eugenio S. Baltao to replace or
make good the dishonored check.
5. Eugenio S. Baltao denied issuing the check and alleged that Guaranteed Industries
was defunct and could not have transacted business with Albenson.
6. Albenson filed a criminal complaint against Eugenio S. Baltao for violation of
Batas Pambansa Blg. 22 (Bouncing Checks Law).
7. Assistant Fiscal Ricardo Sumaway filed an information against Eugenio S. Baltao
based on the criminal complaint.
8. Eugenio S. Baltao filed a motion for reinvestigation, claiming that he was not
properly notified of the complaint and that he never had any dealings with Albenson.
9. Provincial Fiscal Mauro M. Castro reversed the finding of Fiscal Sumaway and
exonerated Eugenio S. Baltao, instructing the Trial Fiscal to move for dismissal of the
information.
10. Eugenio S. Baltao filed a civil case for damages against Albenson Enterprises
Corp., Jesse Yap, and Benjamin Mendiona, alleging abuse of rights under Article 19, 20,
and 21 of the Civil Code.
11. The trial court rendered a decision in favor of Eugenio S. Baltao, ordering the
defendants to pay actual or compensatory damages, moral damages, exemplary damages,
and attorney's fees.
12. The Court of Appeals modified the trial court's decision, reducing the amount of
moral damages and attorney's fees.
13. Albenson Enterprises Corp., Jesse Yap, and Benjamin Mendiona filed a petition
before the Supreme Court, arguing that the civil case was one for malicious prosecution
and that the award of damages and attorney's fees was unwarranted.
14. The Supreme Court reversed the decision of the Court of Appeals, stating that
there was no proof of malicious intent or bad faith on the part of the petitioners in filing
the criminal case against Eugenio S. Baltao.
15. The Supreme Court also found that there was no sufficient evidence to support the
award of actual damages, moral damages, exemplary damages, and attorney's fees.
16. The Supreme Court emphasized that the adverse result of an action does not per se
make the act wrongful and subject the actor to the payment of damages, and that the law
does not impose a penalty on the right to litigate.
17. The Supreme Court concluded that the filing of the criminal case by Albenson
Enterprises Corp. was a sincere attempt to collect the sum of money due to them, and that
there was no malicious intent or abuse of rights on the part of the petitioners.

Issue:
The main issue in this case is whether Albenson Enterprises Corp. should be held liable
for damages for filing a criminal complaint against Eugenio S. Baltao for violation of the
Bouncing Checks Law.’

Ruling:
The Supreme Court ruled in favor of Albenson Enterprises Corp. and reversed the
decision of the Court of Appeals. The Court held that Albenson Enterprises Corp. did not
violate the principle of abuse of rights and did not act maliciously in filing the criminal
complaint against Baltao. The Court emphasized that the filing of the complaint was a
sincere attempt to collect the amount owed to them. The Court also noted that there was
no proof of malicious intent or bad faith on the part of Albenson Enterprises Corp. The
Court further stated that the adverse result of an action does not automatically make the
action wrongful and subject the actor to the payment of damages. Therefore, the Court
concluded that Albenson Enterprises Corp. should not be held liable for damages.

Gi basa ni atty

Assuming, arguendo, that all the three (3) articles, together and not independently of each one,
could be validly made the bases for an award of damages based on the principle of "abuse of right",
under the circumstances, We see no cogent reason for such an award of damages to be made in
favor of private respondent.

Certainly, petitioners could not be said to have violated the aforestated principle of abuse of right.
What prompted petitioners to file the case for violation of Batas Pambansa Bilang 22 against private
respondent was their failure to collect the amount of P2,575.00 due on a bounced check which they
honestly believed was issued to them by private respondent. Petitioners had conducted inquiries
regarding the origin of the check, and yielded the following results: from the records of the Securities
and Exchange Commission, it was discovered that the President of Guaranteed (the recipient of the
unpaid mild steel plates), was one "Eugenio S. Baltao"; an inquiry with the Ministry of Trade and
Industry revealed that E.L. Woodworks, against whose account the check was drawn, was
registered in the name of one "Eugenio Baltao"; verification with the drawee bank, the Pacific
Banking Corporation, revealed that the signature appearing on the check belonged to one "Eugenio
Baltao".

Atty: mao ni damge w/o injury

Atty: Proper exercise of a legal right dili maka result og damage

Andamo vs. Intermediate Appellate Court

G.R. No. 74761

A corporation is held civilly liable for damages caused by the construction of waterpaths
and contrivances within its land, resulting in inundation, erosion, and endangerment of
lives, as ruled by the Supreme Court in the case of Andamo v. Intermediate Appellate
Court.

Facts:
This case involves a dispute between petitioner spouses Emmanuel and Natividad
Andamo and respondent Missionaries of Our Lady of La Salette, Inc. The petitioners own
a parcel of land adjacent to the land owned by the respondent corporation. The petitioners
allege that the respondent corporation constructed waterpaths, water conductors, and
contrivances within its land, which caused inundation, erosion, and damage to the
petitioners' land. The construction also allegedly resulted in the drowning of a young
man, damage to crops and plants, destruction of fences, and endangerment of lives during
rainy and stormy seasons.
The petitioners filed a criminal case against the officers and directors of the respondent
corporation for destruction by means of injunction. They also filed a civil case for
damages against the respondent corporation. The trial court suspended the civil case
pending the resolution of the criminal case. The trial court eventually dismissed the civil
case for lack of jurisdiction, citing the provision of the Rules of Court that prohibits the
institution of a civil action until final judgment has been rendered in the related criminal
action. The dismissal was affirmed by the Intermediate Appellate Court.
Issue:
The main issue in this case is whether the dismissal of the civil case was proper.
Ruling:
The Supreme Court agrees with the petitioners and reverses the decision of the
Intermediate Appellate Court.
Ratio:
The Supreme Court explains that the nature of an action is determined by the facts
alleged in the complaint. In this case, the petitioners' complaint alleges all the elements of
a quasi-delict, namely damages suffered by the plaintiffs, fault or negligence of the
defendant, and the connection of cause and effect between the fault or negligence and the
damages. The Court emphasizes that the use of one's property is not without limitations
and that adjoining landowners have mutual and reciprocal duties to use their land in a
reasonable manner so as not to infringe upon the rights and interests of others. The Court
concludes that the respondent corporation can be held civilly liable for the damages
caused by the construction of the waterpaths and contrivances.
The Court also clarifies that the civil action for quasi-delicts is entirely independent of the
criminal case. The acquittal or conviction in the criminal case is irrelevant in the civil
case, unless the court declares that the fact from which the civil action arose did not exist.
The Court cites previous decisions to support this distinction between civil liability
arising from a crime and responsibility for quasi-delicts.
Therefore, the Supreme Court orders the reinstatement of the civil case and directs the
trial court to proceed with the hearing of the case. The decision is immediately executory.

Our Lady of Lourdes Hospital vs. Spouses Capanzana

A hospital is held liable for negligence after failing to provide timely medical care,
resulting in brain damage to a patient, and is ordered to pay damages to the patient's
family.

Facts:
The case involves Our Lady of Lourdes Hospital, which was held liable for negligence
after failing to provide timely medical care to a patient named Regina Capanzana.
Regina, a 40-year-old nurse and clinical instructor, was scheduled for her third caesarean
section (C-section) but went into active labor a week earlier and was brought to the
hospital for an emergency C-section. After the operation, Regina complained of a
headache, restlessness, and shortness of breath. She requested oxygen, but it took the
nurses about 10 minutes to respond. Regina was eventually transferred to the Intensive
Care Unit and later to another hospital, where it was discovered that she was suffering
from rheumatic heart disease mitral stenosis with mild pulmonary hypertension, which
contributed to the brain damage. Regina's family filed a complaint for damages against
the hospital, the doctors, and the nurses, alleging negligence in providing medical care.
The trial court found the nurses liable for contributory negligence and held the hospital
liable for their negligence. The Court of Appeals affirmed the ruling, finding that the
hospital failed to prove due diligence in the supervision of its nurses. The Supreme Court
affirmed the decision, holding the hospital directly liable for the negligence of its nurses
under the doctrine of corporate responsibility. The court also deducted the unpaid
hospital bill from the damages awarded to the family and imposed interest on the
remaining amount.
Issue:
The main issue raised in the case is whether Our Lady of Lourdes Hospital can be held
directly liable for the negligence of its nurses under the doctrine of corporate
responsibility.
Ruling:
The Supreme Court ruled in favor of Regina Capanzana's family and affirmed the
decision of the lower courts. The hospital was held directly liable for the negligence of its
nurses under the doctrine of corporate responsibility.
Ratio:
The Supreme Court based its decision on the doctrine of corporate responsibility, which
holds that a hospital can be held directly liable for the negligence of its employees,
particularly its nurses, in the performance of their duties. The court emphasized that
hospitals have a duty to ensure the competence and diligence of their employees,
especially those involved in providing medical care. In this case, the hospital failed to
prove due diligence in the supervision of its nurses, as evidenced by the delayed response
to Regina's request for oxygen. The court also noted that the nurses' negligence
contributed to Regina's brain damage, as their failure to provide timely medical care
worsened her condition. Therefore, the hospital should be held directly liable for the
negligence of its nurses.
Furthermore, the court deducted the unpaid hospital bill from the damages awarded to the
family. This deduction is justified because the hospital should not profit from its own
negligence. However, the court imposed interest on the remaining amount to compensate
the family for the delay in receiving the damages. This decision serves as a deterrent for
hospitals to ensure the prompt and proper provision of medical care to their patients.

Vda. de Bataclan vs. Medina

A bus accident leads to the death of passengers, and the court holds the driver and carrier
liable for negligence in failing to prevent the subsequent fire that caused the fatalities.

Facts:
The case of Vda. de Bataclan v. Medina involves a bus accident that occurred on a certain
date and place. The bus, operated by Mariano Medina under the Medina Transportation,
was traveling from Amadeo, Cavite to Pasay City when it experienced a blowout and
overturned into a canal. As a result, some passengers were able to escape, but four
passengers, including Juan Bataclan, were trapped inside the bus. Calls for help were
made, and a group of men arrived with a lighted torch made of bamboo. However, when
they approached the overturned bus, a fire broke out and consumed the bus, resulting in
the death of the trapped passengers.
The plaintiffs, Salud Villanueva Vda. de Bataclan and her minor children, filed a lawsuit
against Mariano Medina seeking compensatory, moral, and exemplary damages, as well
as attorney's fees. The trial court awarded the plaintiffs P1,000 for physical injuries
suffered by Juan Bataclan, P600 as attorney's fees, and P100 for the value of merchandise
lost in the fire. Both parties appealed the decision to the Court of Appeals, which then
endorsed the case to the Supreme Court.
Issue:
The main issue in the case is the liability of the defendant, Mariano Medina, for the death
of Juan Bataclan and the other trapped passengers.
Ruling:
The court ruled that the proximate cause of Bataclan's death was the overturning of the
bus, as it led to the leaking of gasoline from the tank and the subsequent fire. The court
also held that the negligence of the carrier, through its driver and conductor, contributed
to the burning of the bus. The driver and conductor should have known that gasoline
could have leaked from the overturned bus and should have warned the rescuers not to
bring the lighted torch too near the bus. The court found the carrier liable under the
provisions of the Civil Code, particularly Articles 1733, 1759, and 1763.
In terms of the ruling, the court affirmed the decision of the trial court but increased the
damages awarded to the plaintiffs. The court awarded the plaintiffs P6,000 as
compensation for the death of Bataclan, including compensatory, moral, and other
damages. The court also awarded attorney's fees amounting to P800. The court
emphasized the need for the prosecution of the negligent driver in the interest of justice
and the safety of passengers on public utility buses. The decision was also forwarded to
the Department of Justice and the Provincial Fiscal of Cavite for their information and
action.
Ratio:
The court held Mariano Medina, the owner of the bus, liable for the death of Juan
Bataclan and the other trapped passengers. The proximate cause of their death was the
overturning of the bus and the subsequent fire, which could have been prevented through
the exercise of diligence by the carrier's employees. The court awarded increased
damages to the plaintiffs and called for the prosecution of the negligent driver. The court
based its decision on the provisions of the Civil Code, particularly Articles 1733, 1759,
and 1763, which impose a duty of diligence on common carriers to ensure the safety of
their passengers. The court emphasized the importance of holding carriers accountable
for their negligence in order to protect the interests and safety of the public.
Huang vs. Philippine Hoteliers, Inc.

A woman fails to prove negligence on the part of a hotel and its insurer after she is
injured by a falling object, leading to her claim for damages being dismissed by the trial
court and Court of Appeals.

Facts:
The case involves a complaint for damages filed by Dr. Genevieve L. Huang against
Philippine Hoteliers, Inc. (PHI), Dusit Thani Public Co., Ltd. (DTPCI), and First Lepanto
Taisho Insurance Corporation. The complaint was based on the alleged negligence of PHI
and DTPCI's staff in turning off the lights and locking the main entrance door of the
hotel's swimming pool area, which resulted in Dr. Huang being injured by a falling
object. The trial court dismissed the complaint for lack of merit, and this decision was
affirmed by the Court of Appeals.
On June 11, 1995, Dr. Huang and her friend Delia Goldberg were at the Dusit Thani
Hotel Manila swimming pool area. After taking a shower, they found that the area was
already dark and the main entrance door was locked. While trying to find a way out, a
folding wooden counter top fell on Dr. Huang's head, causing her serious brain injury.
Hotel staff eventually arrived and provided medical assistance, but Dr. Huang refused
further medical attention. She later sought treatment from various doctors and claimed
that her injuries were a result of the hotel's negligence.
Issue:
The main issue raised in the case is whether PHI and DTPCI were negligent in their duty
to provide a safe environment for their guests, particularly in the swimming pool area.
Ruling:
The trial court ruled that Dr. Huang failed to prove the negligence of PHI and DTPCI.
The court found that Dr. Huang was aware of the pool's closing time and took the risk of
overstaying. The court also found that Dr. Huang admitted to lifting the folding wooden
counter top, which caused her injury. The court further noted that the hotel staff
immediately responded to the incident and offered medical assistance, but Dr. Huang
refused. The court concluded that Dr. Huang's own negligence was the immediate and
proximate cause of her injury, and therefore, she cannot recover damages.
The Court of Appeals affirmed the trial court's decision, stating that there was no
evidence to support Dr. Huang's claim of negligence on the part of PHI and DTPCI. The
court also found that Dr. Huang failed to sufficiently prove that her current medical
symptoms were a direct result of the head injury she allegedly suffered at the hotel. The
court held that Dr. Huang's claim for damages must fail because she did not establish the
necessary elements of a cause of action for quasi-delict.

Dulay vs. Court of Appeals

A widow and her children file a civil action for damages against a security company and
its employee after the employee shot and killed the widow's husband, alleging negligence
and vicarious liability, leading to the Supreme Court ruling that the complaint stated a
valid cause of action based on the employer's direct and immediate liability under the
Civil Code.

Facts:
The case of "Dulay v. Court of Appeals" involves a civil action for damages filed by
Maria Benita A. Dulay and her minor children against a security company and its
employee. The incident occurred on December 7, 1988, during the "Big Bang sa
Alabang" carnival in Muntinlupa. Atty. Napoleon Dulay was shot and killed by Benigno
Torzuela, a security guard employed by Safeguard Investigation and Security Co., Inc.
and/or Superguard Security Corporation. The widow and her children filed a complaint
alleging negligence and vicarious liability on the part of the defendants. However, the
Regional Trial Court initially dismissed the case, stating that the complaint did not state a
valid cause of action. The Court of Appeals affirmed the dismissal, leading the petitioners
to file a petition for certiorari before the Supreme Court.
Issue:
The main issue in this case is whether the complaint filed by the petitioners states a valid
cause of action against the defendants.
Ruling:
The Supreme Court ruled in favor of the petitioners, reversing the decisions of the lower
courts. The Court held that the complaint sufficiently alleged an actionable breach on the
part of the defendants. It emphasized that Article 2176 of the New Civil Code covers not
only acts committed with negligence but also acts that are voluntary and intentional.
Therefore, even if the shooting incident was intentional, it can still be the basis for a civil
action for damages. The Court also noted that under Article 2180 of the New Civil Code,
employers are directly and immediately liable for the damages caused by their employees
acting within the scope of their assigned tasks. The liability of the employer is not
conditioned upon prior recourse against the negligent employee or a showing of the
employee's insolvency. The Court further explained that the determination of whether the
shooting was reckless or negligent, whether it was within the scope of Torzuela's duties,
and whether the defendants failed to exercise the diligence of a good father of a family
are questions that can be better resolved after trial on the merits. Therefore, the case was
remanded to the Regional Trial Court for further proceedings.