Title
Cangco vs. Manila Railroad Co.
Case
G.R. No. 12191
Decision Date
Oct 14, 1918
Jose Cangco, injured after slipping on watermelons on a dimly lit train platform, sued Manila Railroad Company for negligence. The Supreme Court ruled in his favor, holding the company liable for unsafe conditions and awarding damages for disability and medical expenses.
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Case Digest (G.R. No. 12191)

Facts:

  • Employment and Commute: Jose Cangco, an employee of the Manila Railroad Company, earned a monthly wage of P25. He commuted daily from San Mateo to Manila using a free pass provided by the company.
  • Accident Details: On January 20, 1915, Cangco was returning home. As the train approached San Mateo station, he stood on the steps of the coach while the train was still moving. Upon alighting, he stepped on a sack of watermelons placed on the platform, causing him to slip and fall under the moving train. His right arm was severely injured, requiring two amputations.
  • Platform Conditions: The platform was dimly lit, and the sacks of watermelons were piled close to the edge, obstructing passengers. This obstruction was customary during the melon harvest season.
  • Injuries and Expenses: Cangco suffered permanent disability, losing his job, and incurred medical expenses amounting to P790.25.
  • Lawsuit: Cangco sued the Manila Railroad Company for negligence, claiming the company failed to ensure a safe platform for passengers.

Issue:

  1. Primary Negligence: Was the Manila Railroad Company negligent in placing sacks of watermelons on the platform, creating a hazard for alighting passengers?
  2. Contributory Negligence: Did Cangco contribute to his injury by alighting from the train while it was still in motion?
  3. Legal Liability: Should the company be held liable for damages despite Cangco’s actions?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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