G.R. No. L-9928 - Republic vs. Court of Appeals

On January 27, 1958, at about 8:00 p.m., Genaro N. Teotico was standing in a “loading and unloading” zone at the corner of Old Luneta and P. Burgos Avenue, Manila, waiting for a jeepney.
As he stepped off the curb to board the jeepney, he fell into an uncovered, unlighted catchbasin (manhole). His head struck the rim, breaking his eyeglasses; fragments pierced his left upper eyelid.

Physical injuries included a lacerated left upper eyelid, contusions on the left thigh, left upper arm, right leg, and upper lip, and an abrasion below the right patella. He also suffered allergic eruptions from anti-tetanus injections.
Teotico was treated at the Philippine General Hospital and by a private practitioner (medical expenses: ₱1,400.00). He was incapacitated for 20 days, losing an alleged ₱50.00 per day (₱1,000.00). He endured humiliation, anxiety for his minor children (for whom he was sole support), and incurred counsel fees of ₱2,000.00.

Teotico filed a complaint (later amended) for damages against the City of Manila and several city officers before the Court of First Instance of Manila.
The trial court dismissed the complaint. On appeal, the Court of Appeals affirmed as to the individual officers but held the City of Manila liable for ₱6,750.00 (₱1,400.00 medical fees; ₱350.00 lost income; ₱3,000.00 moral damages; ₱2,000.00 attorney’s fees). The City of Manila then appealed to this Court.

Whether liability of the City of Manila is governed by Section 4 of Republic Act No. 409 (City Charter) or by Article 2189 of the Civil Code (liability for defective public works).

Whether P. Burgos Avenue was under the control or supervision of the City of Manila.
Whether the City exercised the requisite care in maintaining and covering its catchbasins, and thus was negligent.