Docket No. : G.R. No.

L-23052 January 29, 1968

Petitioner: CITY OF MANILA

Respondent: GENARO N. TEOTICO and COURT OF APPEALS, respondents.

Source: https://lawphil.net/judjuris/juri1968/jan1968/gr_l-23052_1968.html

Subject: Statutory Construction

Syllabus/ Part VII: Construction of Conflicting Provisions

Topic: B. Rules on Resolving Statutes in Pari Materia
1. Special Law versus General Law

Facts:

Genaro N. Teotico's unfortunate fall into an uncovered manhole on P. Burgos Avenue, Manila, on
January 27, 1958, resulted in severe injuries, including a lacerated eyelid and multiple contusions. As a
consequence, Teotico took legal action against the City of Manila, alleging negligence in the
maintenance of the road.

His complaint detailed not only the physical injuries but also the significant disruption caused to his
personal and professional life. Teotico, a practicing public accountant, businessman, and university
professor, was unable to work for twenty days following the incident, leading to a loss of income.

Moreover, he endured humiliation and ridicule from peers, experienced constant anxiety about
providing for his minor children, and incurred substantial medical expenses.

In response, the City of Manila contended that it had promptly addressed reports of missing manhole
covers and had not been negligent in its maintenance duties. Despite this, the Court found the City
liable for damages under Article 2189 of the Civil Code, emphasizing the City's control over the road.

Legal Issue: Whether the City of Manila can be held liable for damages under Article 2189 of the Civil
Code due to the defective condition of a road under its control, despite the provision in Republic Act
No. 409 absolving the city from liability for damages arising from negligence of its officers.

Ruling:
The Supreme Court ruled in favor of Genaro N. Teotico and affirmed the decision of the Court of
Appeals, holding the City of Manila liable for damages.

Legal Basis:

In the case provided, Republic Act No. 409 (Charter of the City of Manila) is the special law,
while the Civil Code of the Philippines is the general law.

Article 2189 of the Civil Code imposes liability on provinces, cities, and municipalities for
damages caused by defective conditions of roads, streets, bridges, public buildings, and other
public works under their control or supervision.

Republic Act No. 409 absolves the City of Manila from liability for damages arising from the
failure of its officers to enforce provisions of the law or from negligence in enforcing such
provisions. However, this provision does not exempt the city from liability for damages caused
by defective conditions of roads under its control or supervision.

Republic Act No. 409 specifically addresses the governance and administration of the City of
Manila, including provisions regarding liability for damages arising from the actions or
negligence of city officers. It contains specific provisions applicable only to Manila, making it a
special law.

On the other hand, the Civil Code of the Philippines is a comprehensive body of laws that
govern various aspects of civil relationships, including obligations and contracts. It applies to
the entire country and provides general principles and rules applicable to all provinces, cities,
and municipalities. Therefore, it is considered a general law.
The Court emphasized that Article 2189 is a specific prescription governing liability for defective
streets, while Section 4 of Republic Act No. 409 pertains to liability arising from negligence in general,
regardless of the object thereof.

Even if P. Burgos Avenue were considered a national highway, the City of Manila would still have
control or supervision over it, as evidenced by its legislative powers under Section 18(x) of Republic
Act No. 409.

The determination of whether P. Burgos Avenue is under the control or supervision of the City of
Manila and whether the City is guilty of negligence in maintaining the road are questions of fact, and
the findings of the Court of Appeals on these matters are final and not subject to review.