Facts:

The case involves Manuel S. Araneta and his son, Benjamin Araneta, as plaintiffs and appellants against Juan Arreglado, his wife, and their son, Jose Dario Arreglado, as defendants and appellees. The incident that led to the lawsuit occurred on March 7, 1951, in Manila, where Benjamin Araneta was conversing with fellow students from the Ateneo de Manila while seated on a low wall bordering the school grounds. During this interaction, Dario Arreglado, a former Ateneo student, passed by and was teased about transferring to De La Salle College. In response to the banter, Dario pulled out a Japanese Lugar pistol, which was licensed to his father, Juan Arreglado, and shot Benjamin in the lower jaw. The injury caused Benjamin to fall backward and bleed profusely. He was initially taken to the school infirmary and later to Singian Hospital, where he remained in critical condition for three days before recovering. However, the gunshot left him with a degenerative injury to his jaw an...

Facts:

Background of the Case

• This case involves a personal injury action arising from a shooting incident that resulted in serious bodily harm to plaintiff Benjamin Araneta.
• The incident occurred on March 7, 1951, on the grounds of the Ateneo de Manila when Benjamin, seated atop a low ruined wall, was conversing with his classmates.
• Defendant Dario Arreglado, a former Ateneo student, happened to pass by and, after being teased about his change of school, responded by producing a Japanese Lugar pistol licensed to his father, Juan Arreglado, and firing at Benjamin.

Details of the Injury and Immediate Consequences

• Benjamin Araneta was struck in the lower jaw by the bullet, causing him to fall and suffer profuse bleeding.
• Immediate assistance was rendered; Benjamin was taken to the school infirmary and subsequently to Singian Hospital where he remained in critical condition for three days.
• Although Benjamin eventually recovered, the gunshot resulted in a degenerative injury to his mandible (jawbone) and a prominent facial scar.
• The trauma had a lasting psychological impact, rendering him inhibited and morose after discharge from the hospital.

Criminal Proceedings Involving Dario Arreglado

• Dario Arreglado, aged only 14 at the time of the incident, was indicted for frustrated homicide (Criminal Case No. 15143, Manila) and pleaded guilty.
• The court, considering his youth, suspended the proceedings under Article 80 of the Revised Penal Code and ordered his commitment to the care of Mr. Deogracias Lerma under the supervision of the Commissioner of Social Welfare in accordance with Republic Act No. 47.
• After demonstrating proper conduct and discipline during probation, Dario was discharged on May 22, 1958, leading to the quashing of the criminal case.

The Subsequent Civil Action

• On October 13, 1954, plaintiffs Manuel S. Araneta and his son Benjamin Araneta instituted a civil action against Juan Arreglado, his wife, and their son Dario to recover material, moral, and exemplary damages.
• At trial, the Court of First Instance of Manila (Case No. 24322) found that Juan Arreglado, as father, acted negligently by allowing his minor son access to the firearm.
• The trial court awarded damages amounting to P3,943, along with attorney’s fees, which was significantly below the P112,000 originally claimed by the plaintiffs.
• The trial judge rejected the defense’s contention that a separate civil action was foreclosed because no damages were awarded in the related criminal case.

Appeal and Contention Over the Award

• Although the Arreglado family did not appeal the civil award, the Aranetas appealed on the ground that the award was insufficient given the full extent of Benjamin’s injuries.
• The primary issues on appeal revolved around the need for reparative surgical interventions (including plastic surgery) to address both the degenerative jaw injury and the facial scar.

Issue:

Sufficiency of the Awarded Damages

• Whether the damages awarded by the trial court were adequate to fully compensate Benjamin Araneta for the physical and psychological injuries sustained.
• The inadequacy was particularly highlighted by the failure to include the costs necessary for surgical intervention and plastic surgery to treat the degenerative process in the mandible and the facial scar.

Consideration of Preventive and Corrective Measures

• Whether the lower court erred in not taking into account the realistic and potentially higher costs of corrective surgery, including the possibility of repeated procedures for full rehabilitation.
• The proper allocation of compensation for the permanent deformity and the resultant emotional distress (feelings of inferiority) suffered by the injured party.

The Delay in Pursuing Correct Medical Treatment

• Whether Benjamin’s father’s delay in submitting his son for immediate plastic surgery could be construed as evidence that such treatment was not necessary.
• The contention here addressed the lapse in parental decision-making and its impact, if any, on the rightful recovery of damages.

Scope of Moral Damages Recovery

• Determination of whether the moral damages for pain, anxiety, and suffering of the father could be recovered.
• Examination of precedent (e.g., Strebel vs. Figueras) on the recoverability of moral damages by next of kin in cases of physical injury.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

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