G.R. No. L-4977 – 16 Phil.

18 – Civil Law – Torts and Damages – Elements of

Quasi Delict

David Taylor was a 15 year old boy who spent time as a cabin boy at sea;
he was also able to learn some principles of mechanical engineering and
mechanical drawing from his dad’s office (his dad was a mechanical
engineer); he was also employed as a mechanical draftsman earning P2.50
a day – all said, Taylor was mature well beyond his age.

One day in 1905, he and another boy entered into the premises of Manila
Electric power plant where they found 20-30 blasting caps which they took
home. In an effort to explode the said caps, Taylor experimented until he
succeeded in opening the caps and then he lighted it using a match which
resulted in the explosion of the caps causing severe injuries to his
companion and in Taylor losing one eye.

Taylor sued Manila Electric alleging that because the company negligently
left the caps exposed to children, they are liable for damages.

ISSUE: Whether or not Manila Electric is liable for damages.

HELD: 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 company’s 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 a 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 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.”