Case Summary (G.R. No. L-11394)

Case Background and Incident Overview

• Manuel S. Araneta and his son, Benjamin Araneta, appealed a decision from the Court of First Instance of Manila.
• The case arose from an incident on March 7, 1951, where Benjamin was shot in the jaw by Dario Arreglado, a former student of Ateneo de Manila.
• The shooting occurred after a conversation where Benjamin and others teased Dario about transferring schools.
• Dario used a Japanese Lugar pistol, licensed to his father, Juan Arreglado, resulting in severe injuries to Benjamin, including a degenerative jaw injury and facial scarring.
• Dario was charged with frustrated homicide but was placed under the care of social welfare due to his age (14 years old) and later discharged after good behavior.

Legal Proceedings and Initial Ruling

• On October 13, 1954, the Aranetas filed a civil suit against the Arreglados for damages.
• The trial court found Juan Arreglado negligent for allowing Dario access to the firearm and awarded the Aranetas P3,943 in damages, significantly less than the P112,000 claimed.
• The court dismissed the defense's argument that the lack of damages awarded in the criminal case precluded a separate civil action.

Assessment of Damages and Court's Reasoning

• The appellate court found the damages awarded inadequate, particularly for the permanent deformity and psychological impact on Benjamin.
• The trial court's reasoning that the father’s delay in seeking plastic surgery indicated it was unnecessary was criticized.
• The appellate court emphasized that the physical injuries and scarring were undeniable and required treatment to restore Benjamin's condition.

Consideration of Medical Costs and Future Implications

• The court acknowledged the necessity of surgical intervention, estimating costs at P3,000, excluding hospitalization and other expenses.
• It noted that while local practitioners could perform the surgery, the psychological and physical impacts warranted a higher compensation.
• The court decided to increase the total damages awarded to P18,000, considering the pain, feelings of inferiority, and the nature of the injury.

Moral Damages and Parental Responsibility

• The court reaffirmed that moral damages for physical injuries are recoverable only by the injured party, not by next of kin, unless specified by law.
• The ruling aimed to remind firear...continue reading

Case Syllabus (G.R. No. L-11394)

Case Citation

• Jurisprudence: 104 Phil. 529
• G.R. No. L-11394
• Date of Decision: September 09, 1958

Parties Involved

• Plaintiffs/Appellants: Manuel S. Araneta and Benjamin Araneta
• Defendants/Appellees: Juan Arreglado, his wife, and their son, Jose Dario Arreglado

Background of the Case

• The case arises from an incident on March 7, 1951, involving Benjamin Araneta, a student at Ateneo de Manila.
• Benjamin was seated on a low wall conversing with fellow students when Dario Arreglado, a former Ateneo student, passed by.
• The students engaged Dario in banter about his transfer to De La Salle College, which he resented.
• In a sudden act, Dario pulled a Japanese Lugar pistol, licensed to his father, and shot Benjamin in the lower jaw, resulting in severe injuries.

Injuries and Aftermath

• Benjamin sustained a gunshot wound that caused significant trauma, including:
  • A degenerative injury to the mandible (jawbone).
  • A noticeable facial scar.
• He was hospitalized and under critical condition for three days, eventually recovering but left with lasting physical and emotional effects.
• Dario Arreglado was charged with frustrated homicide but was given probation due to his age (14 years old) and displayed good behavior during his com...continue reading