Cangco v Manila Railroad Co.

G.R. No. 12191, Oct. 14, 1918

Parties:

Jose Cangco – Plaintiff-appellant

Manila Railroad Co. – defendant-appellee

Background:

An employee of MRC got into an accident as he got off the train because of a sack of watermelons in the train
platform.

Claims of complainant Claims of accused

 The company should be liable upon negligence

of servants and employees in placing those sacks
of watermelons in the platform.

Relevant issues:

Lower court:

RTC – The plaintiff failed to use due caution in alighting from the coach and therefore precluded from
recovering. Ruled in favor if the defendant company.

Supreme Court:

Reasoning:

Doctrine:

Manresa clearly points out the difference between “culpa, substantive and independent, which of itself
constitutes the source of an obligation between persons not formerly connected by any legal tie” and culpa
considered as an “accident in the performance of an obligation already existing..”

The liability arising from extra-contractual culpa is always based upon a voluntary act or omission which,
without willful intent, but by mere negligence or inattention, has caused damage to another.