Case Digest (G.R. No. L-36941)
Facts:
The case involves Maria Teresa Y. Cuadra, a 12-year-old minor, who was represented by her father, Ulises P. Cuadra, as plaintiff-appellee, and Alfonso Monfort, defendant-appellant. The incident occurred on July 9, 1962, at Mabini Elementary School in Bacolod City, where both Maria Teresa Cuadra and Maria Teresa Monfort, the daughter of Alfonso Monfort, were classmates in Grade Six. The teacher had assigned a group, including both girls, to weed grass on the school premises. During this activity, Maria Teresa Monfort found a plastic headband and jokingly pretended it was an earthworm, tossing it at Maria Teresa Cuadra. At that moment, Cuadra turned to face Monfort and was hit in the right eye by the headband. Although Cuadra initially treated the injury herself, the eye became swollen the next day, prompting her parents to seek medical attention. She underwent two surgical operations in July and August 1962 and was hospitalized for twenty-three days. Despite treatment, Maria Ter
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Case Digest (G.R. No. L-36941)
Facts:
- Parties
- Plaintiffs-Appellees: Maria Teresa Y. Cuadra, a 12-year-old minor represented by her father, Ulises P. Cuadra, and her parents.
- Defendant-Appellant: Alfonso Monfort, father of Maria Teresa Monfort.
- Incident
- Date and Place: July 9, 1962, Mabini Elementary School, Bacolod City.
- Circumstances: Both minors, Maria Teresa Cuadra (12) and Maria Teresa Monfort (13), were classmates assigned by their teacher, along with three other students, to weed the school grounds.
- Event: While weeding, Monfort found a plastic headband and jokingly declared it an earthworm aloud. To frighten Cuadra, she tossed the object at her. At that precise moment, Cuadra turned around, and the object struck her right eye.
- Injury and Medical Treatment
- Initial Pain: Cuadra felt pain, rubbed her injured eye, and applied powder.
- Progression: The eye swelled the next day, prompting the parents to seek medical attention.
- Treatment: Cuadra underwent two surgical operations (July 20 and August 4, 1962) and was hospitalized for 23 days.
- Expense: Parents incurred medical expenses amounting to P1,703.75.
- Outcome: Despite treatment, Cuadra completely lost sight in her right eye.
- Legal Proceedings
- Suit: The parents filed a civil action for damages against Alfonso Monfort, father of the child who caused the injury.
- Trial Court: The Court of First Instance of Negros Occidental ruled in favor of the plaintiffs, awarding:
- P1,703.00 as actual damages;
- P20,000.00 as moral damages;
- P2,000.00 as attorney’s fees;
- Costs of suit.
- Appeal: Defendant appealed to the Court of Appeals, which then elevated the case to the Supreme Court since the facts were undisputed.
- Relevant Legal Provisions
- Article 2176, Civil Code: Establishes liability for damages caused by act or omission with fault or negligence (quasi-delict).
- Article 2180, Civil Code: Provides parental liability for damages caused by minor children living in their company, with a presumption of fault subject to defense by proof of exercising all diligence of a good father of a family to prevent damage.
Issues:
- Whether Alfonso Monfort is liable for damages caused by the act of his minor daughter under Articles 2176 and 2180 of the Civil Code.
- Whether the defendant exercised "all the diligence of a good father of a family" to prevent the damage and can therefore be exempted from liability.
- Whether the child's act constitutes fault or negligence constituting a quasi-delict.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)