G.R. No. 32611 , November 3, 1930
CULION ICE, FISH AND ELECTRIC CO., INC., plaintiff-appellee, vs. PHILIPPINE MOTORS CORPORATION, defendant-appellant.

FACTS

The plaintiff, Culion Ice, Fish & Electric Co., Inc., owned the motor schooner Gwendoline. Its representative, H.D. Cranston, contracted with the defendant Philippine Motors Corporation, through its manager C.E. Quest, to convert the boat’s engine from a gasoline to a crude oil burner. Quest supervised the work, which included installing a new Zenith carburetor and a temporary fuel tank for an oil-distillate mixture. During the work, fuel leakage and carburetor flooding were observed but dismissed by Quest. On January 30, 1925, during a trial run, a backfire occurred in the engine, igniting the leaked fuel and causing a fire that destroyed the Gwendoline, valued at P10,000 (with only P150 salvage recovered). The plaintiff sued for damages, alleging negligence. The trial court ruled for the plaintiff, awarding P9,850. The defendant appealed, arguing no negligence occurred and that the action was stale.

ISSUE

Whether the defendant corporation is liable for the loss of the Gwendoline due to the negligence or lack of skill of its manager, C.E. Quest, in performing the engine conversion work.

RULING

Yes, the defendant is liable. The Supreme Court affirmed the trial court’s judgment. The Court found that the fire and destruction of the Gwendoline resulted from Quest’s negligence and lack of skill. Although Quest had experience with automobile and tractor engines, he failed to exercise the care and skill expected of one ordinarily skilled in repairing boat engines. The fuel leakage and carburetor flooding created a hazardous condition that a prudent mechanic would have addressed. The backfire, likely due to improper fuel mixture or spark timing, ignited the leaked fuel, causing the fire. This was not an unavoidable accident (casus fortuitus) but a direct consequence of Quest’s blameworthy inadvertence. The Court rejected the trial court’s theory that the defendant was a bailee (shifting the burden of proof) but held that the plaintiff sufficiently proved negligence by a preponderance of evidence. The defense of laches was also dismissed, as the action was filed within the statutory limitation period.