Case Digest (G.R. No. L-23052)
Facts:
City of Manila v. Genero M. Teotico, G.R. No. L-23052, January 29, 1968, the Supreme Court En Banc, Concepcion, C.J., writing for the Court.Petitioner City of Manila sought review of a decision of the Court of Appeals that had imposed liability on the city for injuries sustained by respondent Genero M. Teotico. Teotico alleged that on January 27, 1958, while waiting in a designated loading-and-unloading zone at the corner of Old Luneta and P. Burgos Avenue, he stepped off the curb and fell into an uncovered, unlighted manhole; his fall caused multiple contusions and a laceration to his left upper eyelid from broken eyeglass fragments, required hospitalization and subsequent private treatment costing P1,400, and resulted in lost earnings, moral damages and counsel fees claimed in his suit.
Teotico filed an action for damages in the Court of First Instance (trial court) of Manila against the City of Manila and several city officers. The trial court accepted defendants’ evidence showing police/City Engineer records of prior reports of missing covers and procedures to replace covers, and dismissed the amended complaint, ruling for defendants. On appeal the Court of Appeals affirmed the trial court except as to the City of Manila, which the Court of Appeals held liable and awarded Teotico damages totaling P6,750 (medical fees P1,400; lost income P350; moral damages P3,000; attorney’s fees P2,000).
The City of Manila then appealed to the Supreme Court by certiorari. In its brief and motion for reconsideration below it also contended for the first time that P. Burgos Avenue was a national highway and that Section 4 of Republic Act No. 409 (Charter of the City of Manila) exempted the city from liability; the courts b...(Subscriber-Only)
Issues:
- Is liability for the injuries governed by Section 4 of Republic Act No. 409 or by Article 2189 of the Civil Code?
- Can the City avoid liability on the ground that P. Burgos Avenue is a national highway?
- Was the City of Manila negligent in the maintenance of the street so as ...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)