Title
Teh Le Kim vs. Philippine Aerial Taxi Co., Inc.
Case
G.R. No. 39309
Decision Date
Nov 24, 1933
Passenger injured by propeller after ignoring warnings; court ruled injuries due to his own reckless negligence, absolving airline of liability.
A

Case Summary (G.R. No. 147295)

Facts of the Case

On the day in question, Teh Le Kim purchased a passenger ticket for a flight from Manila to Iloilo on one of the defendant's hydroplanes. Due to engine issues, he experienced delays before being transferred to another plane. Once airborne, the flight proceeded without incident until its arrival at its destination. As the plane landed on the waters of Guimaras Strait, the pilot shut off the gasoline feed pipe for safety reasons, and the plane came to a stop after its pontoons touched the bottom.

The Incident

The pilot was engaged in signaling a banca (small boat) approaching the plane while ensuring safety. During this time, the plaintiff, disregarding safety measures, unfastened his seatbelt and climbed out of the aircraft towards the moving propeller, despite warnings from personnel on the beach. As he approached the propeller, he sustained severe injuries that led to the amputation of his right arm.

Legal Issue

The primary legal question was whether the Philippine Aerial Taxi Co., Inc. fulfilled its contractual duty to provide safe transportation to the plaintiff, as stipulated in their agreement. Specifically, the court evaluated if the defendant had acted negligently in ensuring the safety of passengers during the disembarkation process.

Court's Analysis

The court concluded that the defendant had met its contractual obligations. The established flight procedure required passengers to wait for the propeller to stop before safely exiting the plane. The plaintiff’s premature decision to exit and approach the moving propeller demonstrated a lack of common sense and a significant failure in exercising reasonable care for his own safety.

Finding of Negligence

The ruling clearly stated that the plaintiff acted with reckless negligence. His actions—ignoring safety signals, unbuckling his seatbelt, and approaching a moving propeller—constituted a direct breach of ordinary prudence. The court articulated that the plaintiff’s injuries and subsequent consequences were solely the result of his imprudent be

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