Case Summary (G.R. No. 113658)
Applicable Law and Legal Basis
The case centers on the application of Article 1905 of the Civil Code of the Philippines, which provides that the possessor or user of an animal is liable for any damage caused by the animal, barring exceptions such as force majeure or fault on the part of the injured person. The plaintiff seeks to hold the defendants liable on this basis. The defendants successfully moved for dismissal of the complaint, asserting that the owner is liable only when negligence or fault is proven, especially when the injured party is not a stranger but the caretaker of the animal.
Issue Presented
The primary legal issue is whether the owner or possessor of the animal can be held strictly liable under Article 1905 for injuries caused to the caretaker of the animal, or whether such liability applies only to third parties or strangers. The plaintiff argues for strict liability without the need to establish fault or negligence, while the defendants and the lower court maintain that such liability does not extend to injuries sustained by the caretaker absent proof of fault.
Analysis of Liability Under Article 1905
Article 1905 holds the possessor or user accountable for any damage caused by the animal because they have custody and control over it, which logically places on them the responsibility to prevent harm. However, in this case, the animal was under the control of Loreto Afialda himself, who was the caretaker and voluntarily assumed the risks inherent to this occupation. As the caretaker was employed and compensated to take charge of the animals, the risk of injury was one of the hazards of his employment, and he was presumably in the best position to prevent the harm.
Distinction Between Injury to Stranger and Injury to Caretaker
The court emphasized a crucial distinction: Article 1905 is intended primarily to protect third persons or strangers who are not involved in the custody or care of the animal. This interpretation is supported by prior jurisprudence and commentaries, including cited opinions from the Spanish Supreme Court, which clarifies that injuries to persons engaged in labor-related activities involving the animal are viewed differently. Such injuries have been categorized as occupational hazards and generally fall under labor laws rather than the strict liability provision of Article 1905.
Applicability of Labor Laws and Compensation
The court referred to a Spanish Supreme Court decision recognizing that injuries to employees caused by animals under their charge are “veritable accidents of labor,” which should be treated under labor law frameworks, such as workmen’s compensation, rather than under Article 1905. In the present case, however, the plaintiff did not invoke any labor law remedy or workmen’s compensation, and there was no allegation that the defendants’ business met the financial thresholds specified in relevant labor laws.
Absence of Allegations of Fault or Negligence
Since the plaintiff elected to rely solely on Article 1905 and did not allege fault or negligence on the defendants as required under Article 1902 of the Civil Code, the compla
...continue readingCase Syllabus (G.R. No. 113658)
Nature of the Case and Parties Involved
- This case involves an action for damages arising from an injury caused by an animal.
- The plaintiff, Margarita Afialda, is the elder sister and heir of the deceased, Loreto Afialda.
- The defendants, Basilio Hisole and Francisco Hisole, are spouses who employed the deceased as a caretaker of their carabaos.
- Loreto Afialda was injured on March 21, 1947, when one of the carabaos gored him; he subsequently died as a result of these injuries.
- The complaint alleges that the injury was neither due to Loreto’s own fault nor caused by force majeure.
- Plaintiff seeks to hold defendants liable for damages based on their ownership and control of the animal.
Legal Basis of the Claim: Article 1905 of the Civil Code
- Plaintiff relies on Article 1905 of the Philippine Civil Code, which states: "The possessor of an animal, or the one who uses the same, is liable for any damages it may cause, even if such animal should escape from him or stray away," except when damage arises from force majeure or fault of the injured party.
- The critical issue is whether liability under Article 1905 extends to damages caused to a caretaker employed by the animal’s possessor.
- Plaintiff argues that Article 1905 imposes strict liability on the owner without distinction between strangers and caretakers.
Lower Court’s Ruling and Grounds
- The lower court dismissed the complaint for lack of a cause of action.
- It ruled that Article 1905 imposes liability only for damages caused to strangers, not to persons serving as caretakers of the animal.
- For injuries to a caretaker, the owner’s liability would only arise from fault or negligence under Article 1902 of the Civil Code.
- The court thus held that since no neglige