Case Digest (G.R. No. 4977)
Facts:
David Taylor v. The Manila Electric Railroad and Light Company, G.R. No. 4977, March 22, 1910, the Supreme Court En Banc, Carson, J., writing for the Court.The plaintiff-appellee, David Taylor, a 15-year-old boy, sued The Manila Electric Railroad and Light Company (defendant-appellant) for damages arising from the loss of his right eye and other injuries sustained when a fulminating (detonating) cap he and companions found on the defendant’s premises exploded. Taylor sued by his father as his nearest relative. The action originated in the trial court, which entered judgment for Taylor; the defendant appealed to the Supreme Court.
On Sunday, September 30, 1905, Taylor and a 12-year-old companion crossed a footbridge to Isla del Provisor, the site of defendant’s power plant, to visit an employee. Finding the employee absent, the boys wandered through the company’s uninclosed premises, observed operations (including coal-handling), and discovered some twenty to thirty fulminating caps near the company’s cinder/ash dumping area. The boys picked up the caps, carried them across the bridge, met a girl under nine years old, and together experimented: attempting discharge by an electric socket, trying to break a cap with a stone, opening one with a knife and finally applying a match to the contents. The cap exploded; all three sustained injuries and Taylor ultimately lost an eye.
Evidence showed detonating caps of the same kind had been used a few months earlier on blasting operations at the defendant’s plant and in construction of a streetcar extension; the place where the caps were found served as a dumping ground and the premises were accessible to the public and known to be frequented by children. The defendant did not present rebuttal evidence to show the caps were not its property or that independent contractors alone handled blasting operations. The trial cou...(Pro-only)
Issues:
- Did the plaintiff present sufficient evidence to justify an inference that the fulminating caps were the property of, or under the control of, the defendant and that the defendant negligently left them exposed on its premises?
- If so, is the defendant civilly liable under the Civil Code (arts. 1089, 1902, 1903, 1908) for the injuries suffered by Taylor?
- Was Taylor’s own conduct — cutting open a detonator and applying a match — the proximate cause that bars his recovery despite defendant’s neglige...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
- (Pro-only)