Case Digest (G.R. No. 48006) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
At around 1:30 AM on May 3, 1936, along the road between Malabon and Navotas, Rizal Province, a head-on collision occurred between a taxi owned by petitioner Fausto Barredo and driven by his employee Pedro Fontanilla, and a carretela guided by Pedro Dimapilis. Sixteen-year-old Faustino Garcia, a passenger in the carretela, sustained severe injuries and died two days later. Fontanilla was criminally prosecuted in the Court of First Instance of Rizal for homicide by simple negligence under Article 365 of the Revised Penal Code and sentenced to one year and one day to two years in prisión correccional, reserving the civil action. His conviction was affirmed by the Court of Appeals. On March 7, 1939, the victim’s parents, Severino Garcia and Timotea Almario, filed a separate civil action in the Court of First Instance of Manila against Barredo as Fontanilla’s employer. On July 8, 1939, that court awarded ₱2,000 in damages with legal interest. The Court of Appeals affirmed liability Case Digest (G.R. No. 48006) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioner Fausto Barredo was sole proprietor of the Malate Taxicab, employer of driver Pedro Fontanilla.
- Respondents Severino Garcia and Timotea Almario were the parents of 16-year-old Faustino Garcia.
- Accident and Injury
- On May 3, 1936, about 1:30 AM on the Malabon–Navotas Road, Fontanilla’s taxi collided head-on with a carretela driven by Pedro Dimapilis.
- The carretela overturned, seriously injuring the boy Faustino Garcia, who died two days later.
- Procedural History
- Criminal Case: Fontanilla was convicted of negligence under the Revised Penal Code and sentenced to prison; civil action was expressly reserved.
- Civil Case: On March 7, 1939, respondents sued Barredo in the CFI of Manila and obtained ₱2,000 damages; the Court of Appeals reduced the award to ₱1,000 plus legal interest.
- Employer’s Negligence: It was admitted Barredo employed Fontanilla, who had prior speeding and traffic‐law violations publicized by the Bureau of Public Works.
Issues:
- Can respondents bring a separate civil action directly against Barredo under Civil Code article 1903, without first suing Fontanilla?
- Is Barredo’s liability as employer a primary/direct obligation under the Civil Code, or merely subsidiary under the Revised Penal Code?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)