Case Summary (G.R. No. 160273)
Petitioner
City of Manila, its mayor, city engineer, city health officer, city treasurer and chief of police
Respondent
Genaro N. Teotico and the Court of Appeals
Key Dates
• January 24, 1958 – Report and replacement of a missing catchbasin cover at P. Burgos and Old Luneta Streets
• January 27, 1958 – Teotico’s accident in an uncovered, unlit catchbasin at the same location (about 8:00 p.m.)
• January 30–31, 1958 – Second report and replacement of the catchbasin cover
• January 29, 1968 – Supreme Court decision
Applicable Law
• 1935 Philippine Constitution (governing at the time of decision)
• Republic Act No. 409 §4 (City of Manila Charter)
• Civil Code of the Philippines, Article 2189
• Republic Act No. 917 and Executive Order No. 113 (highway funding and supervision)
Factual Background
On the evening of January 27, 1958, while waiting in a designated loading zone at P. Burgos Avenue and Old Luneta in Manila, Teotico stepped off the curb to board a jeepney. A few steps later he fell into an uncovered, unlit catchbasin. His head struck the rim, shattering his eyeglasses, part of which pierced his left eyelid. Passersby rescued him and brought him to Philippine General Hospital for initial treatment, after which he received follow-up care at home.
Injuries and Damages Sustained
Teotico sustained:
– A laceration of the left upper eyelid (glass fragments embedded)
– Contusions to the left thigh, left upper arm, right leg and upper lip
– An abrasion below the right patella
He incurred P1,400 in private medical fees, lost P350 in income (20 days at P50/day), suffered moral damages (P3,000) for humiliation and anxiety, and agreed to pay P2,000 in attorney’s fees.
Procedural History
Teotico sued the City of Manila and its officers in the Court of First Instance for damages due to the defective catchbasin. The trial court dismissed the amended complaint, finding the City’s storm drain policies reasonable and promptly implemented. On appeal, the Court of Appeals affirmed dismissal as to the individual officers but held the City liable for P6,750 (aggregate of medical fees, lost income, moral damages and attorney’s fees). The City then appealed to the Supreme Court by certiorari.
Issue on Governing Statute
The dispute centered on whether municipal liability is governed by:
- Section 4 of RA 409, which generally exempts the City from damages arising from enforcement negligence by city officers; or
- Civil Code Article 2189, which specifically imposes liability on provinces, cities and municipalities for injuries caused by defective roads, streets, bridges and public works under their control or supervision.
Special vs. General Law Analysis
Although RA 409 is a special law for Manila and the Civil Code a general law, their scope differs: RA 409 §4 addresses liability for enforcement negligence in any context, whereas Article 2189 specifically covers liability for defects in public ways. The latter, being the particular prescription, governs injuries from defective streets.
Liability under Article 2189
Article 2189 requires local government units to answer for personal injuries “by reason of the defective condition of roads, streets, bridges, public buildings, and other public works under their control or supervision.” The accident stemmed from a defect in a street-level public work, bringing the City of Manila within Article 2189’s scope.
National Highway Argument
The City’s contention that P. Burgo
...continue readingCase Syllabus (G.R. No. 160273)
Facts of the Case
- On January 27, 1958, at approximately 8:00 p.m., Genaro N. Teotico stood in a “loading and unloading” zone at the corner of Old Luneta and P. Burgos Avenue, Manila, awaiting a jeepney.
- After about five minutes, a jeepney stopped; as Teotico stepped off the curb and took a few steps, he plunged into an uncovered, unlighted catchbasin (manhole) in the middle of P. Burgos Avenue.
- His head struck the manhole rim, shattering his eyeglasses; fragments pierced his left eyelid, causing profuse bleeding and impaired vision.
- Bystanders extricated Teotico and transported him to the Philippine General Hospital; subsequent treatment was administered both there and by a private practitioner.
Plaintiff’s Background and Injuries
- Teotico was a practicing public accountant, businessman, and university professor, holding positions in multiple firms and civic organizations.
- Injuries sustained included:
- A lacerated wound to the left upper eyelid
- Contusions on the left thigh, left upper arm, right leg, and upper lip
- An abrasion on the right infra-patellar area
- Allergic eruptions from anti-tetanus injections
- These injuries required further private medical treatment costing ₱1,400.00.
Procedural History
- Teotico filed a complaint for damages in the Court of First Instance of Manila against the City of Manila, its mayor, city engineer, health officer, treasurer, and chief of police.
- The complaint alleged negligence in maintaining a public street under the City’s control.
- The trial court dismissed the amended complaint, adopting the defendants’ theory; the Court of Appeals affirmed in part but held the City of Manila liable f