Case Digest (G.R. No. L-29993) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Torio et al. v. Fontanilla et al. (175 Phil. 94, October 23, 1978), petitioners Laudencio Torio, Guillermo Evangelista, Manuel de Guzman, Alfonso R. Magsanoc, Jesus Macaranas, Maximo Manangan, Fidel Montemayor, Melchor Viray, and Ramon Tulagan—members of the 1959 Municipal Council of Malasiqui, Pangasinan—authorized by Resolution No. 159 dated October 21, 1958, the 1959 Malasiqui Town Fiesta to be held on January 21–23, 1959. Resolution No. 182 created an executive committee and a subcommittee on entertainment and stage chaired by Jose Macaraeg, with a P100.00 appropriation to build two bamboo-and-wood stages (one 5½ by 8 meters). On January 22, 1959, an association of Manila Railroad Company employees staged the zarzuela “Midas Extravaganza.” During the performance the rear-supported stage collapsed, pinning actor Vicente Fontanilla, who died the next day. On September 11, 1959, Fontanilla’s heirs sued the Municipality, the municipal council, and its members before the Court Case Digest (G.R. No. L-29993) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Authorization and Preparation for the Fiesta
- On October 21, 1958, the Municipal Council of Malasiqui, Pangasinan, passed Resolution No. 159 authorizing the 1959 town fiesta to be held on January 21–23, 1959, under Section 2282 of the Revised Administrative Code.
- By Resolution No. 182, the Council created the “1959 Malasiqui Town Fiesta Executive Committee” and appointed a subcommittee on entertainment and stage, chaired by Jose Macaraeg, with a P100.00 appropriation for constructing two stages (zarzuela and cancionan).
- Construction and Collapse of the Stage
- The zarzuela stage was built 5½ m by 8 m, with a wooden floor elevated at the rear, supported by 24 bamboo posts (4 front, 4 rear, 5 each side) and bamboo braces.
- On the evening of January 22, 1959, during the performance of “Midas Extravaganza,” the stage collapsed; Vicente Fontanilla, positioned at the rear, was pinned underneath, taken to San Carlos General Hospital, and died the next afternoon.
- Judicial Proceedings
- On September 11, 1959, the heirs of Vicente Fontanilla filed suit for damages in the Court of First Instance (CFI) of Manila, naming the Municipality of Malasiqui, its Municipal Council, and individual councilors as defendants.
- Defendants contended the fiesta was a governmental act immune from tort liability and, alternatively, that they had exercised due diligence; the councilors claimed they acted merely as municipal agents.
- The trial court found that the Executive Committee had exercised due diligence “like a good father of the family” in selecting a competent builder and dismissed the complaint on July 10, 1962.
- On October 31, 1968, the Court of Appeals reversed, holding the municipality and councilors jointly and severally liable for negligence, awarding P12,000.00 in damages, P1,200.00 attorney’s fees, and costs.
Issues:
- Whether the celebration of a town fiesta under Sec. 2282, Revised Administrative Code, is a governmental function (immune from tort liability) or a corporate/proprietary function (subject to liability).
- Whether the Municipality of Malasiqui and its municipal councilors are civilly liable for the death of Vicente Fontanilla due to negligence in stage construction and supervision.
- Whether Article 27, Civil Code, applies to hold councilors personally liable for misfeasance in fiesta preparations.
- Whether the award of attorney’s fees (P1,200.00) was proper under Art. 2208, Civil Code.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)