David Taylor vs Manila Electric Railroad and Light Company

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 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 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.”

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