Case Digest (G.R. No. 137873) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On November 2, 1990 at about 1:30 p.m., Jose A. Juego, a carpenter employed by D.M. Consunji, Inc., was working on a makeshift steel platform at the fourteenth floor elevator core of Tower D, Renaissance Tower Building in Pasig City when the pin connecting the platform to a five-ton chain block became loose—there having been no safety lock—causing the assembly to plunge to the basement and instantly crush him to death while his two companions escaped uninjured. PO3 Rogelio Villanueva of the Eastern Police District conducted an ocular inspection of the site the next day, examined the victim’s remains at the Rizal Medical Center morgue, and filed an official police report on November 25, 1990 reflecting both his personal observations and the statements of witnesses. On May 9, 1991, Maria J. Juego, widow of the deceased, filed a complaint for damages before the Regional Trial Court (RTC) of Pasig City, alleging negligence on the part of her husband’s employer. The RTC rendered judg... Case Digest (G.R. No. 137873) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Accident and Investigation
- On November 2, 1990 at about 1:30 p.m., Jose A. Juego, a carpenter employed by D.M. Consunji, Inc., fell 14 floors to his death while working on a steel-and-plywood platform in the elevator core of Renaissance Tower, Pasig City.
- PO3 Rogelio Villanueva conducted the police investigation. His report (Exhibit “A,” Nov. 25, 1990) described that a bolt merely inserted—without a safety lock—connecting the five-ton chain block to the platform became loose, causing the platform and Jose Juego to plunge into the basement.
- Civil and Appellate Proceedings
- On May 9, 1991, Maria J. Juego, widow of the deceased, sued D.M. Consunji, Inc. in the Regional Trial Court (RTC) of Pasig for damages. The employer pleaded as defense the prior availment by the widow of benefits from the State Insurance Fund (ECC).
- The RTC rendered judgment in favor of the widow, awarding P50,000 (death), P10,000 (actual and compensatory), P464,000 (loss of earning capacity), P100,000 (moral damages), and P20,000 (attorney’s fees).
- On appeal, the Court of Appeals (CA) affirmed in toto. D.M. Consunji, Inc. elevated the case to the Supreme Court, raising four assignments of error regarding:
- Admissibility of the police report as proof of negligence;
- Application of the doctrine of res ipsa loquitur;
- Presumption of negligence under Civil Code Article 2180; and
- Preclusion from Civil Code damages due to prior ECC benefits.
Issues:
- Whether the police investigation report is admissible to prove the truth of its contents or only as part of the investigating officer’s testimony.
- Whether the doctrine of res ipsa loquitur applies, warranting a presumption of negligence.
- Whether D.M. Consunji, Inc. is presumptively negligent under Article 2180 of the Civil Code.
- Whether Maria J. Juego is precluded from recovering Civil Code damages by having availed herself of ECC benefits.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)