G.R. No. L-9308, December 23, 1914
JUAN BERNARDO, plaintiff-appellant, vs. M. B. LEGASPI, defendant-appellee.

FACTS:
Juan Bernardo filed an action in the Court of First Instance of Manila to recover damages for injuries sustained by his automobile due to a collision with the automobile of M. B. Legaspi, allegedly caused by Legaspi’s negligence. Legaspi filed a cross-complaint, seeking damages from Bernardo on the ground that the collision and the resulting injuries to both automobiles were caused by Bernardo’s own negligence in handling his vehicle. The trial court, after evaluating the evidence, found that both Bernardo and Legaspi were negligent in operating their automobiles and that the negligence of each contributed to the accident. Consequently, the court dismissed both the main complaint and the cross-complaint on the merits. Bernardo appealed the dismissal of his complaint.

ISSUE:
Whether either party can recover damages from the other when both the plaintiff and the defendant, through their respective negligence, contributed to the cause of the accident.

RULING:
The Supreme Court affirmed the judgment of the trial court. The Court held that when a plaintiff in a negligence action, through his own carelessness, contributes to the principal occurrence (the accident) as one of its determining causes, he cannot recover damages. This principle applies equally to a defendant in a cross-action. Since the evidence clearly established that both Bernardo and Legaspi were negligent and that their combined negligence proximately caused the collision, neither party is entitled to recover from the other. The judgment dismissing both the complaint and the cross-complaint was therefore correct. Costs were imposed on the appellant.