Case Summary (G.R. No. 143377)
Facts of the Case
David Taylor and a twelve-year-old companion crossed a footbridge onto the company’s premises, seeking an employee named Murphy. Finding him absent, they wandered and observed operations, then discovered twenty to thirty fulminating caps scattered near a cinder dump. The boys collected the caps, carried them home, and conducted experiments—first applying electricity, then attempting to break one with a stone, and finally prying one open with a knife. When Taylor held it and his companion applied a match, it exploded. Taylor lost his right eye; the others received minor injuries.
Legal Issues
- Whether the company was negligent in leaving explosive caps exposed in a place accessible to children.
- Whether Taylor’s own deliberate acts constituted the proximate cause of his injuries, barring recovery despite any company negligence.
Court’s Analysis on Company Negligence
- Ownership and Control: Caps of the same type had been used in company blasting operations and were found on its dump; no evidence contradicted ownership or control.
- Duty of Care: The company knew or should have known that children freely entered and roamed its unenclosed premises. By failing to remove or secure explosive caps, it breached its duty to guard against dangers likely to attract youthful curiosity.
- Implied License: Permitting public access without objection created an implied invitation to enter; under prevailing doctrine, the company owed a duty to safeguard even trespassers of tender years against hidden perils it placed or left behind.
Plaintiff’s Contributory Fault
- Maturity and Capacity: At age fifteen, Taylor was notably mature, trained in mechanics, and employed as a draftsman.
- Knowledge of Danger: His systematic attempts to detonate the cap—using electricity, stone, and knife—demonstrate awareness of its explosive nature. The flight of the nine-year-old girl confirmed his appreciation of risk.
- Willful Act: By deliberately igniting the fulminating material with a match, Taylor performed a reckless, knowing act that directly produced the explosion.
Proximate Cause and Liability
- Contributory Negligence Doctrine: Under Articles 1902 and 1903, liability requires negligence by the defendant or its agents as the proximate cause of damage.
- Intervening Act: Taylor’s intentional ignition constituted an independent, decisive act (“proximate and principal cause”) that severs the causal link from the company’s earlier negligence.
- Comparative Jurisprudence:
Case Syllabus (G.R. No. 143377)
Parties and Procedural Posture
- Plaintiff/Appellee: David Taylor, a 15-year-old minor, suing by his father for damages resulting from loss of an eye and other injuries.
- Defendant/Appellant: The Manila Electric Railroad and Light Company, a foreign corporation operating street railway and electric light systems in Manila.
- Trial Court: Rendered judgment for plaintiff under Civil Code arts. 1089, 1902, 1903, and 1908.
- Supreme Court (G.R. No. 4977, 16 Phil. 8, March 22, 1910): Granted appeal; core contention that plaintiff failed to prove negligence and proximate cause.
Facts
- Premises: Defendant’s power plant on Isla del Provisor, reachable only by boat or a footbridge impassable to vehicles. No fences or prohibitions on pedestrian entry; company aware children frequently roamed the grounds.
- On Sunday, September 30, 1905, David (15) and Manuel Claparols (12) crossed the bridge to visit Murphy, a company employee; Murphy absent, they wandered.
- Near the cinder dump they found 20–30 brass fulminating caps (small electrically-detonated blasting caps) discarded on the ground.
- The boys took the caps, met Jessie Adrian (under 9), and carried the caps to Manuel’s home.
- Experiments conducted: inserting wires in light socket (no detonation), striking with stone (no effect), opening caps with knife, then holding a cap while Manuel applied a match to its contents.
- Explosion occurred: Jessie received a slight neck cut; Manuel’s hand was burned; David was struck by metal fragments, injuring his right eye and necessitating its removal.
- Evidence: Similar caps had been used months earlier in plant construction and in the McKinley extension. No proof caps came from independent contractors; inference drawn they were defendant’s property and were knowingly or negligently left in a public area.
Issues
- Did defendant owe a duty to protect a minor trespasser from explosive materials left exposed on its premises?
- Did the presence and negligent abandonment of the caps constitute the proximate cause of David’s injuries?
- Did Da