Case Digest (G.R. No. L-25906)
Facts:
In Pedro D. Dioquino vs. Federico Laureano, Aida de Laureano, and Juanito Laureano (G.R. No. L-25906, decided May 28, 1970), the automobile of Masbate lawyer Pedro D. Dioquino was borrowed by Patrol Officer Federico Laureano on March 31, 1964, to facilitate vehicle registration at the MVO office in Masbate. While en route to the Provincial Commander’s barracks as the lone passenger, Laureano’s borrowed vehicle was struck by a stone thrown by a mischievous boy, shattering its windshield. Laureano apprehended the boy, but after consulting counsel he refused to pay for the damage, believing the incident to be a fortuitous event under Article 1174 of the 1950 Civil Code. Dioquino filed suit against Federico, his spouse Aida, and his father Juanito, alleging liability for the repair cost. The trial court held Federico liable for P3,000 in damages but absolved Aida and Juanito. All three defendants appealed directly to the Supreme Court, challenging liabilities based on force majeureCase Digest (G.R. No. L-25906)
Facts:
- Background
- Pedro D. Dioquino, a lawyer in Masbate, owned an automobile.
- On March 31, 1964, at the MVO Office in Masbate, he met Patrol Officer Federico Laureano and requested his help to facilitate car registration.
- Incident
- Federico Laureano rode as sole passenger in Dioquino’s car, driven by the plaintiff’s chauffeur, en route to the PC barracks.
- Mischievous boys threw a stone that shattered the windshield. Laureano pursued and caught one boy, who confessed to the act; efforts to settle with the boy’s parents failed.
- Procedural History
- Dioquino sued Federico Laureano for damages and joined his wife, Aida de Laureano, and father, Juanito Laureano, as defendants.
- The trial court held Federico liable and absolved the wife and father.
- All three appealed, raising two legal questions: (a) whether the damage resulted from a fortuitous event excusing liability, and (b) whether Dioquino should be sanctioned for improperly joining the wife and father.
Issues:
- Whether Federico Laureano could be held liable for the broken windshield despite the occurrence being a fortuitous event.
- Whether Plaintiff Dioquino should be ordered to pay damages for having joined his wife and his father in the complaint without sufficient basis.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)