Case Digest (G.R. No. 158589) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Jose Pilapil v. Court of Appeals and Alatco Transportation Company, Inc., petitioner Jose Pilapil, a fare-paying passenger, boarded bus No. 409 of private respondent at San Nicolas, Iriga City, on September 16, 1971, en route to Naga City. While negotiating the Baao cemetery stretch of the national highway in Camarines Sur at about 6:00 P.M., an unidentified bystander hurled a stone through the left window, striking Pilapil above his left eye. The bus personnel promptly conveyed him to the provincial hospital in Naga City, and he later sought treatment in Iriga City and at V. Luna Hospital in Quezon City, but suffered partial loss of vision in his left eye and a permanent scar. He filed Civil Case No. 7230 before the Court of First Instance of Camarines Sur, which awarded him ₱10,000 as actual damages, ₱5,000 as moral and exemplary damages, ₱300 for medical expenses and ₱1,000 for attorney’s fees. Private respondent appealed to the Court of Appeals (CA-G.R. No. 57354-R), and Case Digest (G.R. No. 158589) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the Trip
- On 16 September 1971 at about 6:00 P.M., petitioner Jose Pilapil, a paying passenger, boarded Alatco Transportation Co. bus No. 409 at San Nicolas, Iriga City, Camarines Sur.
- The bus was en route from Iriga City to Naga City along the national highway.
- Stoning Incident and Injury
- Near the Baao cemetery, an unidentified bystander hurled a stone through the bus’s left window, striking petitioner above his left eye.
- Alatco personnel promptly brought petitioner to the provincial hospital in Naga City; subsequent treatment included one week with Dr. Malabanan (Iriga City) and convalescence at V. Luna Hospital in Quezon City under Dr. Capulong.
- Despite treatment, petitioner suffered partial loss of vision in the left eye and a permanent scar.
- Judicial Proceedings
- Petitioner filed Civil Case No. 7230 in the Court of First Instance of Camarines Sur seeking damages.
- Trial court rendered judgment awarding:
- ₱10,000.00 for actual/material damages,
- ₱5,000.00 for moral and exemplary damages,
- ₱300.00 for medical expenses,
- ₱1,000.00 for attorney’s fees, plus costs (total ₱16,300.00).
- Defendant appealed to the Court of Appeals (CA-G.R. No. 57354-R), which on 19 October 1979 reversed and set aside the trial court’s decision.
- Petitioner filed this petition for certiorari before the Supreme Court to review the CA decision.
Issues:
- Whether a common carrier is liable for passenger injuries caused by the wilful act of a stranger (stoning) during transport.
- Whether the respondent transportation company successfully rebutted the presumption of negligence imposed by law.
- Whether the carrier should be held to a standard of installing precautionary devices (e.g., window meshwork) to guard against unlawful acts of strangers.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)