Civil Aeronautics Administration vs. Court of Appeals

G.R. No. 51806
Simke sued CAA for damages after slipping on a hazardous elevation at Manila Airport; Court ruled CAA negligent, not immune, and awarded damages.
damages slipping and falling dangerous elevation

Case Digest (G.R. No. 51806)

Facts:

Civil Aeronautics Administration v. Court of Appeals and Ernest E. Simke, G.R. No. 51806, November 08, 1988, Supreme Court Third Division, Cortes, J., writing for the Court.

Petitioner Civil Aeronautics Administration (CAA) was sued by private respondent Ernest E. Simke, a naturalized Filipino and then Honorary Consul General of Israel, for injuries he sustained on the viewing terrace of the Manila International Airport (MIA). On December 13, 1968, while watching incoming passengers from the terrace, Simke slipped over an elevation about four inches high, fell on his back and suffered a fractured thigh that required surgery the next day.

Simke filed a quasi-delict action in the Court of First Instance of Rizal, Branch VII, seeking reimbursement of medical and hospital expenses and consequential damages (including costs for two lawyers who had to travel abroad in his stead and publication notices for a postponed wedding). The trial court found for Simke and awarded P15,589.55 for medical and hospital expenses, P20,200.00 consequential damages, P30,000.00 moral damages, P40,000.00 exemplary damages, P20,000.00 attorney’s fees, and costs.

The Court of Appeals affirmed the trial court’s decision and denied the CAA’s motion for reconsideration. The CAA then filed a petition for review on certiorari before the Supreme Court assailing (1) that CAA, as a government agency, was immune from suit without consent of the Republic, (2) that there was insufficient evidence of negligence, and (3) that the damages awarded were not supported by substantial evidence.

Both the trial court and this Court conducted ocular inspections of the terrace; the courts found the elevation to be a dangerous, slanting “step” with missing tiles and other defects, and noted lack of maintenance and absence of warning sig...(Pro-only)

Issues:

  • Is the Civil Aeronautics Administration immune from suit as an arm of the State, or may it be sued for quasi-delict?
  • Did the CAA commit negligence that proximately caused Ernest E. Simke’s injuries?
  • Were the awards of actual, consequential, moral and exemplary damages, and attorney’s fees, sup...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)
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