Title
Taylor vs. Manila Electric Railroad and Light Co.
Case
G.R. No. 4977
Decision Date
Mar 22, 1910
A 15-year-old boy, David Taylor, suffered severe injuries after experimenting with explosive caps found on the defendant’s unsecured premises. The court ruled the defendant negligent but held Taylor’s actions as the proximate cause, barring recovery due to contributory negligence.

Case Digest (G.R. No. 101005)
Expanded Legal Reasoning Model

Facts:

  • Parties and setting
    • Plaintiff/Appellee: David Taylor, a 15-year-old minor represented by his father; son of a mechanical engineer, mature and trained in mechanics.
    • Defendant/Appellant: Manila Electric Railroad and Light Company, a foreign corporation operating a street railway and electric light system in Manila; power plant located on Isla del Provisor, accessible only by boat or a narrow pedestrian bridge.
  • Chronology of the accident
    • September 30, 1905 (Sunday): Taylor and Manuel Claparols (12 years old) cross the footbridge seeking Murphy, a company employee; Murphy absent.
    • Boys wander company premises, observe coal-handling crane, then find 20–30 brass fulminating (detonating) caps scattered in a cinder-dump area. They hang caps on a stick, each boy carrying one end.
    • After crossing back, they meet Jessie Adrian (
    • Taylor holds an opened cap; Manuel applies a lighted match, causing an explosion. Injuries: Taylor loses right eye; Manuel’s hand burned; Jessie receives slight neck cut.
  • Premises conditions and company knowledge
    • Similar caps used months earlier in well-sinking on company premises and in track-extension work; no evidence of contractor independence.
    • Caps appeared discarded as defective among ashes and cinders; no fencing or warnings; children known to roam freely on the uninclosed grounds.
    • Company offered no rebuttal; inference drawn that caps belonged to or were under control of the defendant and left negligently.
  • Plaintiff’s background and recovery
    • Taylor had served four months as a cabin boy; later worked as mechanical draftsman (₱2.50/day) one month after injury.
    • Described as taller, more mature, and above-average intelligence for his age.

Issues:

  • Basis of liability under the Philippine Civil Code
    • Whether defendant’s act or omission in leaving explosive caps exposed constitutes negligence per Arts. 1089, 1902, 1903, and 1908.
    • Whether the causal link (“proximate cause”) exists between that negligence and plaintiff’s injury.
  • Effect of plaintiff’s own conduct and age
    • Applicability of the Turntable/Torpedo doctrine: duty owed to child trespassers when owner knows children will enter.
    • Whether Taylor’s deliberate act of igniting the cap breaks the chain of causation and constitutes contributory negligence barring recovery.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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