16 Phil.

18 – Civil Law – Torts and Damages – Element – Quasi Delicts

David Taylor vs Manila Electric Railroad and Light Company
Digest
Facts:
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 to the explosion of the caps causing severe injuries to his companion
and to Taylor losing one eye.
Taylor sued Manila Electric alleging that because the company left the caps exposed to
children, they are liable for damages due to the company’s negligence.
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 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.”