Case Digest (G.R. No. 147746) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 1986, Gaudencio Sarangaya III and Primitiva B. Sarangaya constructed a semi-concrete, semi-narra one-storey commercial building called Super A Building fronting the provincial road of Santiago, Isabela, subdivided into three units. Behind two of these units stood their two-storey residence. In 1988, Perla Compania de Seguros, Inc., through its branch manager Bienvenido S. Pascual, leased the first unit, converting half into an office and the other half into a garage for a 1981 Ford Cortina used by Pascual on company business. On July 10, 1988, Pascual attempted to start the vehicle after a few days’ absence; upon revving the engine he noticed odd sounds and saw flames erupting from the rear compartment. The blaze engulfed the garage and spread to the Sarangayas’ residence, causing personal injuries to Pascual and destroying buildings, furniture, appliances, jewelry and cash. A fire marshal’s report classified the incident as accidental and noted lack of a fire permit. A crimi... Case Digest (G.R. No. 147746) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Construction and Lease
- In 1986, spouses Gaudencio Sarangaya III and Primitiva B. Sarangaya erected the “Super A Building,” a semi-concrete, single-storey commercial structure with three doors, and a two-storey residence behind doors II and III, fronting the Santiago, Isabela provincial road.
- In 1988, Perla Compania de Seguros, Inc., through its branch manager Bienvenido S. Pascual, leased door I, renovated it into office and garage space, and used the garage to park a company-provided 1981 Ford Cortina.
- Incident and Damages
- July 10, 1988: Pascual, after attempting to start the car, observed flames from the engine compartment, alighted, and pushed the car out; fire erupted from the rear compartment, engulfing the garage and trapping Pascual, who suffered burns.
- The fire spread to respondents’ adjoining residence, destroying the building and personal property; the city fire marshal ruled the fire “accidental” and noted absence of a fire permit.
- Procedural History
- Criminal complaint for reckless imprudence filed against Pascual; later withdrawn. Respondents filed a civil action in quasi-delict for actual, moral, exemplary damages and attorney’s fees.
- RTC awarded ₱2,904,880 actual damages, applying res ipsa loquitur against Pascual and vicarious liability against the corporation; CA affirmed liability but reduced award to ₱600,000 nominal damages, then on motion remanded case for additional evidence on actual damages. Petitioners sought certiorari relief.
Issues:
- Did the Court of Appeals err in applying the doctrine of res ipsa loquitur?
- Did the Court of Appeals err in finding Perla Compania de Seguros, Inc. vicariously liable for lack of supervision of its employee?
- Did the Court of Appeals err in remanding the case to the RTC for reception of additional evidence on actual damages?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)