SUPREME COURT REPORTS ANNOTATED
Wright v Manila Electric R.R & Light Co
I. Recit-ready summary
Petitioner-plaintiff: E.M. Wright
Respondent-defendant: Manila Electric R.R & Light Co
Cause of action: Damages
Plaintiff was going home intoxicated in his calesa. There were ill-
maintained rails of defendant’s train tracks before his house and the
horse stumbled on it, causing plaintiff to be thrown off the calesa. He
sued for damages.
The trial court ruled that both parties were negligent but the
plaintiff’s was not as great as defendant’s, thus awarding the amount
of P1000 to the plaintiff.
WON plaintiff was negligent? No.
There is nothing in the opinion (of the trial court) that sustains the
conclusion that the plaintiff was negligent with reference to the
accident. Mere intoxication is not negligence, nor does the mere
fact of intoxication establish a want of ordinary care. It is but a
circumstance to be considered with the other evidence tending to
prove negligence. It is the general rule that it is immaterial
whether a man is drunk or sober if no want of ordinary care or
prudence can be imputed to him, and no greater degree of care is
required to be exercised by an intoxicated man for his own
protection than by a sober one. If one’s conduct is characterized by
a proper degree of care and prudence, it is immaterial whether he is
drunk or sober.
Petition denied.
II. Facts of the case
The defendant (Manila Electric) is a corporation engaged in
operating an electric street railway in Manila City, including
G.R. NO:
ARTICLE; TOPIC OF CASE: Concept of Negligence (contributory negligence)
VOL # [October 1, 1914]
Wright v Manila Electric R.R & Light Co
Caloocan. The plaintiff’s (Wright) residence in Caloocan fronts on
the street along which defendant’s tracks run, so that to enter his
premises from the street, plaintiff is obliged to cross defendant’s
tracks.
On the night of the accident, plaintiff drove home in a calesa and in
crossing the tracks to enter, the horse stumbled, leaped forward, and
fell, causing the vehicle to strike one of the rails with great force and
throwing plaintiff, causing the injuries complained of.
The point where the plaintiff crossed the tracks on the night in
question had its rails above-ground, but that the ties upon which the
rails rested projected from the ground, this making the tops of the
rails higher than the level of the street.
It was admitted that the defendant was negligent in maintaining its
tracks as described, but it is contended that the plaintiff was also
negligent as he was intoxicated at the time of the accident and that
such intoxication was the primary cause of the accident.
The trial court held that both parties were negligent, but that the
plaintiff’s negligence was not as great as defendant’s. The TC
awarded damages in favor of plaintiff in the amount of P1000.
III. Issue/s
WON the plaintiff was negligent and if yes, to what extent. No,
he was not negligent.
IV. Ratio/Legal Basis
Negligence.
There is nothing in the opinion (of the trial court) that sustains the
conclusion that the plaintiff was negligent with reference to the
accident. Mere intoxication is not negligence, nor does the mere
PONENTE:Moreland
DIGEST MAKER:Lim
 SUPREME COURT REPORTS ANNOTATED
Wright v Manila Electric R.R & Light Co
fact of intoxication establish a want of ordinary care. It is but a
circumstance to be considered with the other evidence tending to
prove negligence. It is the general rule that it is immaterial whether a
man is drunk or sober if no want of ordinary care or prudence can be
imputed to him, and no greater degree of care is required to be
exercised by an intoxicated man for his own protection than by a
sober one. If one’s conduct is characterized by a proper degree of
care and prudence, it is immaterial whether he is drunk or sober.
No facts are stated in the opinion which warrant the conclusion that
the plaintiff was negligent. The conclusion that if he had been sober
he would not have been injured is not warranted by the facts as
found. It is impossible to say that a man would not have fallen from
the vehicle under the conditions described.
It having been found that the plaintiff was not negligent, it is
unnecessary to discuss the question presented by the appellant
company with reference to the applicability of the case of Rakes (in
the award of damages) and we do not find facts in the opinion of the
court below which justify a larger verdict than the one found.
V. Disposition
Petition denied.
VI. Notes
There was a finding of fact that, in fact, he was
intoxicated? No.
And then he died?
No, but he was injured.
Manila Electric was negligent or not negligent?
Negligent.
Because?
G.R. NO:
ARTICLE; TOPIC OF CASE: Concept of Negligence (contributory negligence)
VOL # [October 1, 1914]
Wright v Manila Electric R.R & Light Co
It admitted that it was negligent in maintaining its tracks.
But?
Manila Electric contended that Wright was also negligent in that he was
intoxicated, and thus, was unable to take care of himself properly and that such
intoxication was the primary cause of the accident.
So, that’s why CFI mitigated or reduced the damages awarded in favor of Wright.
Then, this case was elevated to the SC. What did the SC say? Was Wright
negligent?
No. The SC said that mere intoxication is not necessarily negligence.
So, what is it? If it’s not negligence?
It is just one of the circumstances to be considered in ascertaining whether a
person was negligent.
GR: If one's conduct is characterized by a proper degree of care and prudence, it is
immaterial whether he is drunk or sober.
Atty. Jess Lopez: Because it’s possible that regardless of intoxication, it may still be
possible that ordinary care was observed.
SC Ruling: Regardless of whether he was drunk or sober, the SC held that the
accident would have still happened because of the faulty maintenance of Manila
Electric’s tracks.
Going back to the TC, the TC found that the cause of accident was Manila
Electric’s negligence, but at the same time, the TC found that Wright was guilty
of contributory negligence. The SC found that Wright was not guilty of any
negligence, not even contributory negligence. Right?
Yes.
And therefore, because the TC used contributory negligence as a basis to reduce
the amount of damages awarded, in turn, the SC, because it found that there
was no contributory negligence, it increased the amount of damages awarded to
Wright? No.
Why not?
PONENTE:Moreland
DIGEST MAKER:Lim
 SUPREME COURT REPORTS ANNOTATED VOL # [October 1, 1914]
Wright v Manila Electric R.R & Light Co Wright v Manila Electric R.R & Light Co

The SC still did not find facts that would justify a larger amount.

G.R. NO: PONENTE:Moreland

ARTICLE; TOPIC OF CASE: Concept of Negligence (contributory negligence) DIGEST MAKER:Lim