Title
Araneta vs. Arreglado
Case
G.R. No. L-11394
Decision Date
Sep 9, 1958
A 14-year-old shot a student, causing severe injuries. The shooter, placed on probation, was later discharged. The victim’s family sued for damages, with the Supreme Court increasing compensation to cover medical costs and psychological harm, emphasizing firearm owner responsibility.
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Case Digest (G.R. No. L-11394)

Facts:

Incident Details

  • On March 7, 1951, Benjamin Araneta, a student at Ateneo de Manila, was seated on a low ruined wall bordering the Ateneo grounds along Dakota Street, Manila, conversing with other students.
  • Dario Arreglado, a former Ateneo student who had transferred to De La Salle College, passed by and was teased by the group about his transfer.
  • Arreglado, angered by the banter, pulled out a Japanese Lugar pistol (licensed in his father Juan Arreglado’s name) and shot Benjamin Araneta in the lower jaw.
  • Benjamin was severely injured, requiring immediate medical attention. He was taken to the school infirmary and later to Singian Hospital, where he remained in critical condition for three days.
  • Benjamin eventually recovered but suffered permanent damage to his jawbone (mandible) and a facial scar. He also experienced psychological effects, becoming inhibited and morose.

Criminal Proceedings

  • Dario Arreglado was charged with frustrated homicide (Criminal Case No. 15143) and pleaded guilty.
  • Due to his age (14 years old), the court suspended the proceedings under Article 80 of the Revised Penal Code and placed him under probation under the supervision of the Commissioner of Social Welfare.
  • After demonstrating good behavior during probation, Dario was discharged on May 22, 1958, and the criminal case was quashed.

Civil Action

  • On October 13, 1954, Manuel S. Araneta (Benjamin’s father) and Benjamin filed a civil case against Juan Arreglado, his wife, and Dario to recover material, moral, and exemplary damages.
  • The Court of First Instance found Juan Arreglado negligent for allowing his son access to the pistol and awarded P3,943 in damages and attorney’s fees.
  • The Aranetas appealed, arguing that the damages awarded were inadequate, given the severity of Benjamin’s injuries and the costs of necessary medical treatments.

Issue:

  1. Whether the damages awarded by the lower court were adequate to compensate Benjamin Araneta for his injuries, including the costs of surgical and plastic surgery treatments.
  2. Whether the father’s delay in seeking plastic surgery for his son should affect the son’s right to full indemnity.
  3. Whether moral damages should be awarded to Manuel Araneta for the pain and suffering caused by his son’s injury.
  4. Whether the lost school year and potential reduction in Benjamin’s future earning capacity warranted additional damages.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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