Facts:

The case of Juan Bahia vs. Fausta Litonjua and Mariano Leynes revolves around a tragic incident that occurred on May 16, 1911, in Balayan, Batangas. The plaintiff, Juan Bahia, sought damages for the death of his daughter, who was killed when an automobile, driven by a chauffeur employed by Mariano Leynes, struck her. The automobile in question was owned by Fausta Litonjua, the mother of Ramon Ramirez, who managed the International Garage in Manila. Prior to the accident, Fausta purchased the automobile and entrusted it to her son’s garage for business purposes. On May 14, 1911, Ramirez rented the automobile to Leynes, along with a chauffeur and a machinist, for a short-term use during a local fiesta. The arrangement stipulated that Leynes would pay Ramirez P20 per day for the use of the vehicle. On the day of the accident, while traveling from Balayan to Tuy, the automobile malfunctioned due to a defect in the steering gear, causing it to veer off course and collide with a wa...

Facts:

Parties and Background

• Plaintiff and Appellant: Juan Bahia, who brought the action to recover damages.
• Defendants and Appellants/Apellees:
• Fausta Litonjua, defendant and appellee, mother of Ramon Ramirez.
• Mariano Leynes, defendant and appellant.
• Non-party Involvement:
• Ramon Ramirez, owner and manager of the International Garage, whose actions and management of the automobile are central to the case, though he was not made a party to the suit.

Transaction and Use of the Automobile

• Acquisition and Turnover
• Fausta Litonjua purchased an automobile and subsequently turned it over to her son Ramon Ramirez’s garage—the International Garage in Manila—for business use.
• By turning over the automobile, ownership rights in a formal sense were isolated from managerial control, which then passed to Ramirez.
• Contractual Arrangement with Leynes
• On May 14, 1911, Ramirez rented the automobile, along with a chauffeur and a machinist, to Mariano Leynes.
• The terms of the contract stipulated a rental fee of P20 per day for Leynes to operate the automobile for transportation purposes between Balayan and Tuy, Batangas, specifically to serve passengers for an impending local fiesta.

The Accident and Its Immediate Circumstances

• Occurrence of the Accident
• On May 16, 1911, while Leynes was operating the automobile between Balayan and Tuy, a defect in the steering gear of the vehicle led to loss of control.
• Specifically, when attempting to negotiate a corner in the streets of Balayan, the malfunctioning mechanism prevented the driver from altering the course as required.
• Consequences of the Defect
• The automobile, failing to obey the intended direction, struck a house’s wall.
• At the moment of impact, the front of the automobile fatally crushed the plaintiff’s daughter who was leaning against the wall.

Claims and Procedural History

• Cause of Action
• The plaintiff initiated an action to recover damages for the death of his daughter, attributing her death to the negligence of the defendants.
• The defendants against whom the action was brought were Fausta Litonjua (as owner who had turned over the vehicle) and Mariano Leynes (under whose direction the automobile was operated at the time of the accident).
• Lower Court Judgments and Appeals
• The Court of First Instance of Manila rendered decisions against Leynes (ordering payment of P1,000 with costs) and dismissed the complaint against Fausta Litonjua.
• The appeals were taken by Leynes, contesting the judgment for damages, and by the plaintiff (Bahia), challenging the dismissal of the claim against Fausta Litonjua.

Issue:

Liability of the Parties Involved

• Whether Fausta Litonjua, though the purchaser of the automobile, could be held responsible for the negligence leading to the tragic accident given that she had turned over the vehicle to her son’s garage for management and use.
• Whether Mariano Leynes should be held liable for the accident due to his authority and control over the operation of the automobile, notwithstanding the demonstrated absence of prior notice of the defect.

Application of Negligence Principles

• Whether the presumption of negligence arising from the operation of an automobile with a defective steering gear should automatically attach to Leynes as his agent or operator, or if he could rebut such presumption by showing he exercised due care.
• The extent to which Article 1903 of the Civil Code applies—specifically, whether Leynes met the standard of exercising “all the diligence of a good father of a family” to avoid damage, despite the inherent defect in the vehicle.

Allocation of Responsibility between Master and Servant

• The issue of whether Leynes could escape liability by demonstrating that the selection and supervision of employees (the chauffeur and the machinist) and the maintenance of the machine were conducted with proper diligence.
• How the principles of Spanish law on negligence, as contrasted with American doctrines, impact the determination of liability when a servant’s negligence potentially implicates the master.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)