Title
Picart vs. Smith, Jr.
Case
G.R. No. L-12219
Decision Date
Mar 15, 1918
Amado Picart sued Frank Smith, Jr. for negligence after a 1912 bridge collision. Smith failed to avoid the accident despite warning Picart, who was on a pony. The Supreme Court ruled Smith liable, applying the "last clear chance" doctrine, awarding Picart damages for injuries and loss.

Case Digest (G.R. No. L-12219)
Expanded Legal Reasoning Model

Facts:

  • Parties and Procedural History
    • Plaintiff–Appellant: Amado Picart, seeks P31,100 for damages allegedly caused by an automobile.
    • Defendant–Appellee: Frank Smith, Jr.; absolved by the Court of First Instance of La Union; appeal lodged.
  • Accident Particulars
    • Date and Place: December 12, 1912, on Carlatan Bridge, San Fernando, La Union (approx. 75 m long, 4.80 m wide).
    • Sequence of Events:
      • Picart was midway on the bridge riding a pony.
      • Smith approached in an automobile at ~10–12 mph, sounding his horn before and during bridge crossing.
      • Upon hearing the signals, Picart pulled his pony close to the right railing, fearing insufficient time to clear.
      • Smith steered toward the left (correct side) assuming the pony would move; when he perceived the pony would not clear, he swerved sharply but remained too close.
      • The pony was frightened, turned across the bridge, was struck on the left hind hock by the car flange, broke its leg, fell, and later died; Picart suffered contusions requiring medical treatment.
  • Prior Proceedings
    • Lower Court: CFI of La Union absolved Smith of civil liability.
    • Criminal Action: Picart filed for “lesiones graves” before a justice of the peace; dismissed at preliminary hearing.

Issues:

  • Did Smith’s conduct amount to actionable negligence?
  • Does Picart’s antecedent negligence bar or reduce his recovery?
  • Is the “last clear chance” doctrine applicable?
  • Did the justice-of-peace dismissal operate as res judicata on civil liability?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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