G.R. No. L-14335; January 28, 1920
MANUEL DE GUIA, plaintiff-appellant, vs. THE MANILA ELECTRIC RAILROAD & LIGHT COMPANY, defendant-appellant.

FACTS:
On September 4, 1915, Dr. Manuel de Guia boarded a streetcar of The Manila Electric Railroad & Light Company (MERALCO) in Caloocan. Shortly after departure, the rear wheels of the car derailed upon exiting a switch, causing the car to strike a concrete post. De Guia, who was standing on the back platform, was thrown against a door and sustained injuries. He filed an action for damages against MERALCO. The trial court found MERALCO liable through the negligence of its motorman and awarded De Guia P6,100 as damages. Both parties appealed the decision.

ISSUE:
1. Whether MERALCO was liable for the damages suffered by De Guia.
2. Whether the damages awarded by the trial court were proper and in accordance with law.

RULING:
The Supreme Court modified the trial court’s decision, affirming liability but reducing the damages awarded.

1. On Liability: The Court sustained the finding of negligence on the part of MERALCO’s motorman. Regardless of whether the derailment was initially caused by a stone on the track (casus fortuitus), the motorman was negligent in failing to detect the derailment promptly and in allowing the car to travel a considerable distance before striking the post. The relationship between De Guia and MERALCO was contractual (carrier-passenger). Consequently, MERALCO was liable for breach of its contractual obligation to transport passengers safely under Articles 1103-1107 of the Civil Code. The defense under the last paragraph of Article 1903 (due diligence in selection and supervision of employees) was inapplicable, as that provision governs extra-contractual liability (culpa aquiliana), not contractual breach.

2. On Damages: The Court applied the principle that for contractual liability involving good faith (as MERALCO was found to be a debtor in good faith under Article 1107), recoverable damages are limited to those foreseeable at the time the obligation was contracted and are the necessary result of the breach.
Loss of Earnings: The award of P900 for three months’ loss of professional income (at P300/month) was sustained, though deemed liberal.
Loss of Prospective Employment: The award of P3,900 for the alleged loss of a district health officer position was disallowed for being speculative and unforeseeable.
Medical Expenses:
P200 paid to Dr. Montes was allowed.
* Charges from three other physicians were disallowed. Their services appeared gratuitous (as professional courtesy) and were deemed unnecessary for treatment but rather procured to bolster the lawsuit.

Additional Procedural Note: The Court also held that the medical certificates presented by De Guia’s physicians were inadmissible as primary evidence, being hearsay. Their proper use was merely to refresh a witness’s memory.

DISPOSITIVE PORTION:
The judgment was MODIFIED. MERALCO was ordered to pay Manuel de Guia the reduced amount of One Thousand One Hundred Pesos (P1,100), with legal interest from November 8, 1916. The modified judgment was AFFIRMED.