Case Summary (G.R. No. L-11394)
Case Overview
- This case involves an appeal by Manuel S. Araneta and Benjamin Araneta against a decision of the Court of First Instance of Manila regarding damages awarded for injuries sustained by Benjamin Araneta.
- The original claim was for P112,000, but the trial court awarded only P3,943 in damages.
Factual Background
- On March 7, 1951, Benjamin Araneta was shot by Dario Arreglado while conversing at the Ateneo de Manila.
- Dario, aged 14, shot Benjamin with a licensed firearm owned by his father, Juan Arreglado, after being taunted about his departure from Ateneo.
- Benjamin sustained serious injuries, resulting in a degenerative condition and a facial scar.
Criminal Proceedings
- Dario Arreglado was indicted for frustrated homicide but the court suspended proceedings due to his age, placing him under the care of social welfare authorities.
- He was eventually discharged after demonstrating good behavior.
Civil Proceedings
- Following the incident, the Aranetas filed a civil suit for damages against the Arreglados.
- The trial court found Juan Arreglado negligent for allowing access to the firearm but awarded inadequate damages.
Legal Principles and Findings
- Negligence and Liability: Juan Arreglado was held responsible for his son’s actions due to negligence in firearm supervision.
- Damages Awarded: The court ruled that the damages awarded were insufficient given the physical and psychological impacts on Benjamin.
- Moral Damages: The court clarified that only the injured party can claim moral damages, not relatives.
- Indemnity Amount: The Supreme Court increased the awarded damages to P18,000, recognizing the need for corrective surgeries and psychological impact.
Key Legal Provisions
- Article 80 of the Revised Penal Code: Provides for the suspension of criminal proceedings against minors.
- Article 2194 of the Civil Code of the Philippines: Pertains to solidary liability for damages.
Important Details
- Damages Breakdown:
- Initial award by trial court: P3,943.
- Adjusted damages by the Supreme Court: P18,000, encompassing surgical and psychological treatment costs.
- Negligence Finding:
- Juan Arreglado’s failure to secure the firearm led to liability.
Key Takeaways
- The Supreme Court recognized the inadequacy of the damages awarded, emphasizing the importance of proper supervision of firearms and the need for comprehensive treatment for injuries caused by negligence.
- The ruling affirms that moral damages are limited to the injured party, reinforcing a legal precedent on recovery in cases of ph
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 commitment.