Case Digest (G.R. No. L-59463) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Romulo Abrogar and Erlinda Abrogar are the parents of the late Rommel Abrogar, an eighteen-year-old minor who joined the 1st Pop Cola Junior Marathon held on June 15, 1980 in Quezon City. The event was organized and supervised by Intergames, Inc. and sponsored by Cosmos Bottling Company, Inc., and mapped a ten-kilometer course along public roads from the Interim Batasang Pambansa to the Quezon City Hall Grandstand via Don Mariano Marcos Avenue. Although police authorities permitted the race only on condition that the route remain open to vehicular traffic, Intergames proceeded without blocking off the highway, relying on volunteer marshals, barangay tanods and police detailees for safety. During the run, Rommel was struck by a passenger jeepney engaged in a roadside contest with other vehicles and died later that day from head injuries. On October 28, 1980 the Abrogars sued Cosmos and Intergames for damages in what was then the Court of First Instance of Rizal. On May 10, 1991, ... Case Digest (G.R. No. L-59463) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Organization of the Marathon
- Cosmos Bottling Company (Cosmos) sponsored the “1st Pop Cola Junior Marathon,” held on June 15, 1980 in Quezon City; Intergames, Inc. (Intergames) was the sole organizer and had full control over race logistics.
- A 10-kilometer route was plotted from the Interim Batasang Pambansa Lane, through Don Mariano Marcos Avenue, ending at the Quezon City Hall compound; police permitted the event only if the road remained open to vehicular traffic.
- Accident and Death of Rommel Abrogar
- Rommel Abrogar, an 18-year-old minor, registered and participated in the race wearing an official number; no road closures, barriers, or adequate coordination of marshals prevented mixed running and vehicular flow.
- While running alongside other participants, Rommel was struck in the head by a jeepney racing a competing minibus; he received medical attention at Ospital ng Bagong Lipunan but died later that day from severe head injuries.
- Procedural History
- Petitioners (Rommel’s parents) sued Cosmos and Intergames in 1980 for actual and compensatory damages, loss of earning capacity, moral and exemplary damages, attorney’s fees and litigation expenses.
- The Regional Trial Court (RTC) in 1991 found both respondents jointly liable, awarding P28,061.63 actual damages, P100,000 moral, P50,000 exemplary damages, and 10% attorney’s fees.
- The Court of Appeals (CA) in 2004 reversed the RTC, absolving both respondents: it held Intergames not negligent (ordinary diligence was exercised), applied assumption of risk, and ruled Cosmos as mere sponsor without liability.
- Petitioners elevated the case to the Supreme Court, challenging (a) finding of no negligence by Intergames; (b) applicability of assumption of risk; (c) absolution of Cosmos; and (d) denial of damages for loss of earning capacity and other awards.
Issues:
- Whether Intergames was negligent in staging the marathon and whether such negligence was the proximate cause of Rommel’s death.
- Whether Cosmos, as financial sponsor, can be held jointly and severally liable with Intergames.
- Whether the doctrine of assumption of risk bars petitioners’ recovery.
- Whether petitioners are entitled to damages for loss of earning capacity, and to the actual, moral, exemplary damages and attorney’s fees awarded by the RTC.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)