Case Digest (G.R. No. 51806) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Civil Aeronautics Administration v. Court of Appeals and Ernest E. Simke, decided November 8, 1988, the private respondent, Ernest E. Simke—a naturalized Filipino and former Honorary Consul General of Israel—visited the Manila International Airport viewing terrace on December 13, 1968, to meet his future son-in-law. While traversing a crowded terrace, Simke stepped on an unnoticed four-inch elevation in the tiled pavement, slipped, fell on his back, and fractured his thigh bone. He underwent surgery the following day. Simke filed a quasi-delict action with the Court of First Instance of Rizal against the Civil Aeronautics Administration (CAA), the government agency tasked under R.A. 776, Sec. 32(24), to operate and maintain the airport. He sought P15,589.55 for medical and hospital expenses, P20,200.00 in consequential damages for business-related delays and publication costs, P30,000.00 in moral damages, P40,000.00 in exemplary damages, and P20,000.00 in attorney’s fees. The Case Digest (G.R. No. 51806) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Incident
- Private respondent Ernest E. Simke, a naturalized Filipino and Honorary Consul General of Israel, went with others to the Manila International Airport’s viewing deck on December 13, 1968, to meet his future son-in-law.
- While walking on the crowded terrace, Simke slipped over an approximately four-inch elevation, fell on his back, and sustained a fractured thigh bone, necessitating a three-hour surgery on December 14, 1968.
- Procedural History
- Simke filed a quasi-delict action in the Court of First Instance of Rizal, Branch VII, against the Civil Aeronautics Administration (CAA), claiming actual medical and hospital expenses (P15,589.55), consequential damages (P20,200.00 for lawyers’ travel and publication notices), moral damages (P30,000.00), exemplary damages (P40,000.00), attorney’s fees (P20,000.00), interest, and costs.
- The trial court rendered judgment in Simke’s favor; the CAA appealed to the Court of Appeals, which affirmed; a motion for reconsideration was denied; the CAA then elevated the case to the Supreme Court via petition for review on certiorari.
Issues:
- Whether the CAA, as a government agency, enjoys immunity from suit without the State’s consent.
- Whether the CAA was negligent in constructing and maintaining the viewing-deck elevation and failed to exercise due diligence.
- Whether the awards of actual, consequential, moral, exemplary damages, and attorney’s fees were supported by substantial evidence and applicable law.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)