Title
Astudillo vs. Manila Electric Co.
Case
G.R. No. 33380
Decision Date
Dec 17, 1930
Astudillo died after touching an exposed wire near a public area; Meralco found negligent for inadequate safety measures, but damages reduced.
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Case Digest (G.R. No. 33380)

Facts:

  1. Incident Overview:

    • In August 1928, Juan Diaz Astudillo died from electrocution after touching a wire connected to an electric light pole near Santa Lucia Gate, Intramuros, Manila.
    • The pole was located in a public area frequented by people for leisure and relaxation.
  2. Location and Surroundings:

    • The Santa Lucia Gate area is a public space near significant structures like the Ateneo de Manila, Agustinian Convent, Bureau of Public Works, and Santa Lucia Barracks.
    • The area is open to the public, with no prohibitory signs or barriers to prevent access.
  3. Electric Pole and Wires:

    • The electric pole was erected in 1920 and last inspected in 1923 or 1924.
    • The wires were of the insulated type (triple braid weatherproof) as required by the franchise.
    • The pole was close enough to the public area that a person could reach out and touch the wires.
  4. Circumstances of the Accident:

    • On August 14, 1928, Juan Diaz Astudillo and a companion were near the electric pole.
    • Astudillo placed his foot on a projection, reached out, and grasped a charged wire, resulting in instant death.
  5. Legal Action:

    • Astudillo’s mother filed a lawsuit against the Manila Electric Company (Meralco) for damages amounting to P30,000.
    • Meralco defended itself by claiming Astudillo’s death was due to his own negligence and that it had exercised the diligence of a good "father of a family" to prevent harm.
  6. Trial Court Decision:

    • The Court of First Instance of Manila ruled in favor of the plaintiff, awarding P15,000 in damages.

Issue:

  1. Whether the Manila Electric Company was negligent in maintaining the electric pole and wires, leading to Astudillo’s death.
  2. Whether Astudillo’s own negligence contributed to the accident.
  3. Whether the plaintiff, as the mother of the deceased, was entitled to damages despite not being an acknowledged natural child under the Civil Code.
  4. Whether compliance with the franchise and ordinances absolves Meralco of liability.

Ruling:

The Supreme Court modified the trial court’s decision, reducing the damages to P1,500. The Court held:

  1. Meralco was negligent in placing the electric pole and wires in a public area without adequate precautions to prevent human contact.
  2. Astudillo’s actions were not negligent but were the natural behavior of someone unaware of the danger.
  3. The plaintiff, as the mother of the deceased, was entitled to damages despite not being an acknowledged natural child under the Civil Code.
  4. Compliance with the franchise and ordinances does not absolve Meralco of liability if ordinary care and diligence were not exercised.

Ratio:

  1. Negligence of Electric Companies:

    • Electric companies must exercise a high degree of care commensurate with the danger posed by electricity. This duty extends to all places where people have a right to be.
    • Proper insulation and placement of wires are necessary to prevent injuries, especially in areas frequented by the public.
  2. Contributory Negligence:

    • Astudillo’s act of touching the wire was not negligent but a natural act of someone unaware of the danger. The risk of such an accident was foreseeable and should have been guarded against.
  3. Liability Despite Compliance with Franchise:

    • Compliance with a franchise or ordinance does not automatically absolve a company of negligence. The fulfillment of minimum legal requirements does not negate the need for ordinary care.
  4. Damages for Next of Kin:

    • The mother of the deceased, even if not an acknowledged natural child under the Civil Code, is entitled to damages for the death caused by negligence.
    • The Court awarded P1,500 based on precedents and the circumstances of the case, including the deceased’s age and the expenses incurred.

Dissent

Justice Johnson dissented, arguing that there was no evidence of negligence on the part of Meralco. He believed the judgment should be revoked entirely.


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