Taylor v. Manila Electric Railroad and Light Co.

G.R. No. L-4977, March 22 1910

Doctrine: The just thing is that a man should suffer the damage which comes to him
through his own fault, and that he cannot demand reparation therefor from another.

Maria Guila Renee S. Baldonado

Facts:
September 30, 1905 Sunday afternoon: David Taylor, 15 years of age, the son of a
mechanical engineer, more mature than the average boy of his age, and having considerable
aptitude and training in mechanics with a boy named Manuel Claparols, about 12 years of
age, crossed the footbridge to the Isla del Provisor, for the purpose of visiting Murphy, an
employee of the defendant, who and promised to make them a cylinder for a miniature
engine.

After leaving the power house where they had asked for Mr. Murphy, they walked
across the open space in the neighborhood of the place where the company dumped in the
cinders and ashes from its furnaces. They found some twenty or thirty brass fulminating
caps scattered on the ground. These caps are approximately of the size and appearance of
small pistol cartridges and each has attached to it 2 long thin wires by means of which it
may be discharged by the use of electricity.They are intended for use in the explosion of
blasting charges of dynamite, and have in themselves a considerable explosive power.

The boys picked up all they could find, hung them on stick, of which each took end,
and carried them home. After crossing the footbridge, they met Jessie Adrian, less than 9
years old, and they went to Manuel's home. The boys then made a series of experiments
with the caps. They thrust the ends of the wires into an electric light socket however no
result. They also tries to brake the cap with a stone but it failed. They try to open one of the
caps with a knife, and finding that it was filled with a yellowish substance they got matches.
David held the cap while Manuel applied a lighted match to the contents. An explosion
followed, causing more or less serious injuries to all three. Jessie, who when the boys
proposed putting a match to the contents of the cap, became frightened and started to run
away, received a slight cut in the neck. Manuel had his hand burned and wounded. David
was struck in the face by several particles of the metal capsule, one of which injured his
right eye to such an extent as to the necessitate its removal by the surgeons.

Plaintiff appears to have rested his case, as did the trial judge his decision in plaintiff's
favor, upon the provisions of article 1089 of the Civil Code read together with articles
1902, 1903, and 1908 of that code.

Counsel for the defendant and appellant rests his appeal strictly upon his contention that
the facts proven at the trial do not established the liability of the defendant company
under the provisions of these articles

Issue:
Whether or not Manila Electric is libel to Taylor for damages under the Civil Code.
Rule/Law:

ART. 1908 The owners shall also be liable for the damage caused -
By the explosion of machines which may not have been cared for with due diligence, and for
kindling of explosive substances which may not have been placed in a safe and proper place.

Application:

No. The SC reiterated the elements of quasi delict as follows: (1) Damages to the
plaintiff. (2) Negligence by act or omission of which defendant personally, or some person for
whose acts it must respond, was guilty. (3) The connection of cause and effect between the
negligence and the damage.
In the case at bar, it is true that Manila Electric has been negligent in disposing off the
caps which they used for the power plant, and that said caps caused damages to Taylor.
However, the causal connection between the companys negligence and the injuries sustained
by Taylor is absent. It is in fact the direct acts of Taylor which led to the explosion of the caps
as he even, in various experiments and in multiple attempts, tried to explode the caps. It is from
said acts that led to the explosion and hence the injuries.
Taylor at the time of the accident was well-grown youth of 15, more mature both
mentally and physically than the average boy of his age; he had been to sea as a cabin boy; was
able to earn P2.50 a day as a mechanical draftsman thirty days after the injury was incurred;
and the record discloses throughout that he was exceptionally well qualified to take care. The
evidence of record leaves no room for doubt that he well knew the explosive character of the
cap with which he was amusing himself. The series of experiments made by him in his attempt
to produce an explosion admit of no other explanation. His attempt to discharge the cap by the
use of electricity, followed by his efforts to explode it with a stone or a hammer, and the final
success of his endeavors brought about by the applications of a match to the contents of the
cap, show clearly that he knew what he was about. Nor can there be any reasonable doubt that
he had reason to anticipate that the explosion might be dangerous.
The law fixes no arbitrary age at which a minor can be said to have the necessary capacity
to understand and appreciate the nature and consequences of his own acts, so as to make it
negligence on his part to fail to exercise due care and precaution in the commission of such
acts; and indeed it would be impracticable and perhaps impossible so to do, for in the very
nature of things the question of negligence necessarily depends on the ability of the minor to
understand the character of his own acts and their consequences. Tylor was sui juris in the
sense that his age and his experience qualified him to understand and appreciate the necessity
for the exercise of that degree of caution which would have avoided the injury which resulted
from his own deliberate act; and that the injury incurred by him must be held to have been the
direct and immediate result of his own willful and reckless act, so that while it may be true that
these injuries would not have been incurred but for the negligence act of the defendant in
leaving the caps exposed on its premises, nevertheless plaintiff's own act was the proximate
and principal cause of the accident which inflicted the injury.
The rule of the Roman law was: Quod quis ex culpa sua damnum sentit, non intelligitur
sentire. Just thing is that a man should suffer the damage which comes to him through his own
fault, and that he can not demand reparation therefor from another. Negligence is not presumed,
but must be proven by him who alleges it.