Case Digest (G.R. No. 129792) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Jarco Marketing Corporation, Leonardo Kong, Jose Tiope and Elisa Panelo vs. Hon. Court of Appeals, Conrado C. Aguilar and Criselda R. Aguilar (G.R. No. 129792, December 21, 1999), the petitioners owned and managed the Syvelas Department Store in Makati City where on May 9, 1983 six-year-old Zhieneth Aguilar was playing near a gift-wrapping counter on the second floor. The counter, shaped like an inverted “L” and unbolted to the floor, collapsed and pinned her to the ground. She sustained severe intra-abdominal injuries, underwent surgery, lost her speech, and died on May 22, 1983. Her parents, Conrado and Criselda Aguilar, sued in the Makati RTC (Civil Case No. 7119) for medical, funeral, and moral damages. The RTC dismissed the Aguilars’ complaint, finding contributory negligence on the part of Mrs. Aguilar and her daughter and no defect in the counter. On appeal, the CA reversed, held the counter defective, absolved the Aguilars of negligence and awarded actual, moral, exem Case Digest (G.R. No. 129792) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Context
- Petitioners:
- Jarco Marketing Corporation, owner of Syvelas Department Store, Makati City.
- Leonardo Kong (branch manager), Jose Tiope (operations manager), Elisa Panelo (supervisor).
- Private respondents:
- Conrado and Criselda Aguilar, parents of six‐year‐old Zhieneth Aguilar.
- Incident and Aftermath
- On 9 May 1983, Criselda and Zhieneth were at the second‐floor gift‐wrapping counter. A sudden gust or movement caused the counter to collapse, pinning Zhieneth.
- Zhieneth was rushed to Makati Medical Center, underwent surgery, lost her speech the next day, and died fourteen days later (22 May 1983) from intra‐abdominal injuries (lacerated liver, ruptured stomach, transected duodenum, retroperitoneal hematoma, lung contusion).
- Procedural History
- Private respondents filed Civil Case No. 7119:
- Claimed P157,522.86 actual damages, P300,000 moral damages, P20,000 attorney’s fees, unspecified damages for loss of income and exemplary damages.
- Petitioners’ defense:
- Denied liability, alleged contributory negligence of Criselda and Zhieneth.
- Asserted due diligence in maintaining a sturdy, long‐standing counter.
- Trial Court (RTC Makati, Branch 60, 15 January 1992):
- Dismissed complaint and counterclaim, finding petitioners non‐negligent; proximate cause was Zhieneth’s misbehavior and Criselda’s negligence.
- Court of Appeals (17 June 1996):
- Reversed RTC, held petitioners negligent for maintaining an unstable, top‐heavy counter.
- Found Zhieneth incapable of contributory negligence (under nine years).
- Awarded P99,420.86 actual damages, P50,000 compensatory damages, P100,000 moral and exemplary damages, P20,000 attorney’s fees.
- CA Resolution (16 July 1997): Denied petitioners’ motion for reconsideration.
- Petitioners filed a petition for review on certiorari under Rule 45 before the Supreme Court.
Issues:
- Nature of the Event
- Was Zhieneth’s death an accident or attributable to negligence?
- Attribution of Negligence
- If negligence is found, was it due to petitioners’ maintenance of a defective counter or to Criselda’s and Zhieneth’s failure to exercise due care?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)