326771686-01-Cariaga-vs-LTB-Co-and-MRR.docx - Cariaga vs LAGUNA TAYABAS BUS COMPANY and MANILA RAILROAD COMPANY Dizon J G.R No L-11037 Doctrine Damages

326771686-01-Cariaga-vs-LTB-Co-and-MRR.docx - Cariaga vs...

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Cariaga vs. LAGUNA TAYABAS BUS COMPANY and MANILA RAILROAD COMPANY Dizon, J. December 29, 1960 G.R. No. L-11037 Doctrine Damages recoverable from common carriers; Actual or compensatory – An obligor guilty of a breach of contract in good faith is liable under Art. 2201, NCC for such damages which are the “natural and probable consequences of the breach and which the parties had foreseen at the time the obligation was constituted,” provided such damages, according to Art. 2199 of the same Code, have been duly proved. This would be the premise for the award of actual damages. However, in increasing the award for compensatory damages, the Court also took in consideration the income Cariaga would have earned had he been able to finish his studies and pass the Board because they could have reasonably been foreseen by the parties at the time he boarded the bus No. 133 owned and operated by the LTB. Summary Cariaga, a medical student, was on board the LTB bus bound for Laguna when, upon reaching the train crossing, it bumped the engine of the moving train of the MRR. He was hospitalized for his serious injuries which reduced his intelligence and made him incapable of finishing his studies. He sued the LTB and MRR for actual, compensatory, exemplary, and moral damages and attorney’s fees. The trial court held LTB liable for compensatory damages. The Supreme Court held that the MRR was not guilty of contributory negligence and that its driver made many warnings upon the crossing. The SC increased the award of compensatory damages, taking into account the income he should have earned had he been able to finish his studies and pass the boards (which is now impossible because of his injuries). Moral damages, compensatory damages, and attorney’s fees weren’t granted, however, since the cause of action did not arise out of a quasi-delict resulting to physical injuries.
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