Case Digest (G.R. No. 12191)
Facts:
In Jose Cangco vs. Manila Railroad Co., decided October 14, 1918, the plaintiff, Jose Cangco, was employed as a clerk by the Manila Railroad Company at a monthly wage of ₱25 and lived in San Mateo, Rizal, along the defendant’s rail line. He held a free-ride pass and on the evening of January 20, 1915, he alighted from the slowly moving second-class coach at the San Mateo station. Unbeknownst to him, railroad employees had stacked heavy sacks of watermelons along the edge of the cement platform under dim illumination, leaving only about two feet of clear space. When Cangco stepped off the coach, his foot struck a melon, causing him to fall, be drawn under the car, and suffer a crushed right arm, which ultimately required two successive amputations near the shoulder. He incurred ₱790.25 in medical expenses and filed suit on August 31, 1915, in the Court of First Instance of Manila. The trial court found that the Railway Company had been negligent in placing the sacks but barred reCase Digest (G.R. No. 12191)
Facts:
- Employment and travel context
- Jose Cangco was employed as a clerk by the Manila Railroad Company, earning ₱25 per month, and lived in San Mateo, Rizal. He used a company-issued pass to travel free of charge on the railroad’s trains.
- On January 20, 1915, between 7 and 8 p.m., Cangco rode in a second-class car from Manila toward San Mateo. As the train neared the station, he rose, exited through the door, and stood on the coach steps, holding the upright guardrail for support.
- Platform conditions and obstruction
- The San Mateo station platform was a cement structure rising gradually from ground level, extending the length of several coaches, and was dimly lighted by a single distant lamp.
- During melon‐harvest season, numerous tow sacks of watermelons had been piled along the platform in a row, leaving only about two feet of clear space from the platform edge.
- Accident, injuries, and procedural history
- After another passenger alighted safely at the beginning of the platform rise, Cangco stepped off the moving train (which advanced some six meters before stopping), his foot struck a melon in the sacks, he slipped, fell onto the platform, and was drawn under the car. His right arm was badly crushed and lacerated.
- He was rendered unconscious, taken to a Manila hospital where his arm was amputated, then to a second hospital for a higher‐level amputation. His medical and related expenses totaled ₱790.25.
- On August 31, 1915, he sued the railroad for negligence in the Court of First Instance, alleging that its servants unlawfully obstructed the platform. The trial court found defendant negligent but held Cangco contributorily negligent in alighting from a moving train, and dismissed his claim. Cangco appealed.
Issues:
- Defendant’s liability under the contract of carriage
- Did the Manila Railroad Company breach its contractual duty to provide a safe means of egress by allowing dangerous obstructions on the platform?
- Can the company avoid contractual liability by showing due care in the selection and supervision of its servants under Civil Code Articles 1902–1903?
- Plaintiff’s contributory negligence
- Does stepping off a moving train constitute negligence per se that bars recovery?
- If both parties were negligent, how should damages be apportioned under the doctrine of comparative negligence?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)