Title
Bahia vs. Litonjua
Case
G.R. No. 9734
Decision Date
Mar 31, 1915
Plaintiff sued for damages after daughter's death caused by rented automobile accident; court dismissed claims against owner and renter, finding no negligence.
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Case Digest (G.R. No. 9734)

Facts:

  1. Background of the Case:

    • The plaintiff, Juan Bahia, filed a lawsuit to recover damages for the death of his daughter, allegedly caused by the negligence of the defendants' servant in driving an automobile that struck and killed her.
    • The defendants were Fausta Litonjua (who purchased the automobile) and Mariano Leynes (who rented the automobile and employed the chauffeur).
  2. Ownership and Use of the Automobile:

    • Fausta Litonjua purchased an automobile and turned it over to her son, Ramon Ramirez, who managed the International Garage in Manila.
    • On May 14, 1911, Ramirez rented the automobile, along with a chauffeur and a machinist, to Mariano Leynes for use during a fiesta in Tuy, Batangas. Leynes agreed to pay P20 per day for the service.
  3. The Accident:

    • On May 16, 1911, while traveling from Balayan to Tuy, the automobile's steering gear malfunctioned, causing it to veer off course and strike the plaintiff's daughter, who was leaning against a house wall. The impact killed her instantly.
  4. Legal Proceedings:

    • The plaintiff sued both Fausta Litonjua and Mariano Leynes for damages.
    • The trial court dismissed the case against Fausta Litonjua but held Mariano Leynes liable for P1,000 in damages. Both the plaintiff and Leynes appealed the decision.

Issue:

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Ruling:

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Ratio:

  1. Presumption of Negligence:

    • Under Article 1903 of the Civil Code, a presumption of negligence arises against an employer when an injury is caused by the negligence of a servant or employee. However, this presumption is rebuttable.
  2. Rebuttal of Presumption:

    • The employer can overcome the presumption by proving that they exercised the care and diligence of a good father of a family in selecting and supervising the servant or employee.
    • In this case, Leynes demonstrated that he obtained the automobile from a reputable garage, employed licensed and competent personnel, and had no knowledge of the defect in the steering gear.
  3. Distinction from American Doctrine:

    • The Spanish law of negligence, as applied in the Philippines, bases the employer's liability on their own negligence, not conclusively on the negligence of the servant. This differs from the American doctrine, which holds the master conclusively liable for the servant's negligence in relations with third parties.
  4. Outcome:

    • The court held that Leynes was not liable because he exercised due diligence, and the accident was caused by a defect in the automobile for which he was not responsible.


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