Title
Lasam vs. Smith, Jr.
Case
G.R. No. 19495
Decision Date
Feb 2, 1924
A contractual carrier is liable for passenger injuries caused by vehicle defects or driver negligence, not a fortuitous event, with damages reasonably awarded.
A

Case Digest (G.R. No. L-24225)

Facts:

HONORIO LASAM ET AL., husband and wife, sued FRANK SMITH, JR. for damages in an action arising from an automobile accident on February 27, 1918; the trial court awarded P1,254.10 with legal interest, and both parties appealed. The defendant operated a public garage and carried passengers for hire from San Fernando, La Union; the plaintiffs were being conveyed to Currimao when the chauffeur yielded to an unlicensed assistant, the car later zigzagged after crossing the Abra River at Tagudin, ran down an embankment and overturned, injuring Mrs. Joaquina Sanchez severely; the record shows the case was tried largely on tort theory under article 1903, but the trial court held the action contractual and applied articles 1101-1107 of the Civil Code.

Issues:

  • Is the defendant liable for the injuries under the contract of carriage or excused by *caso fortuito* under article 1105 of the Civil Code?
  • Did the trial court err in awarding only P1,254.10 instead of the P7,832.80 claimed by the plaintiffs?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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