ELEMENTS OF

QUASI DELICT
 DAVID TAYLOR VS.
THE MANILA ELECTRIC RAILROAD AND LIGHT
COMPANY
G.R. NO. L-4977 MARCH 22, 1910
• 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.
 “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.”

• 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.

 “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.”

• 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.
 HEIRS OF PEDRO TAYAG, SR VS. HONORABLE
FERNANDO S. ALCANTARA, PHILIPPINE RABBIT BUS
LINES, INC. & ROMEO VILLA Y CUNANAN
G.R. NO. L-50959 JULY 23, 1980
• FACTS:
• In the afternoon of September 2, 1974, while Pedro Tayag Sr. was riding on a bicycle along MacArthur

Highway at Bo. San Rafael, Tarlac, Tarlac on his way home, he was bumped and hit by a Philippine Rabbit Bus

bearing Body No. 1107 and Plate No. YL 604 PUB '74, driven by Romeo Villa, as a result of which he sustained

injuries which caused his instantaneous death.

• Thus, petitioner heirs (Crisanta Salazar, Pedro Tayag, Jr., Renato Tayag, Gabriel Tayag, Corazon Tayag and

Rodolfo Tayag) filed with the CFI Tarlac a complaint for damages against the private respondents Philippine

Rabbit Bus Lines, Inc. and Romeo Villa.

• On April 30, 1975, the private respondents filed a motion to suspend the trial on the ground that the criminal

case against the driver of the bus Romeo Villa was still pending in said court, and that Section 3, Rule III of the

Revised Rules of Court enjoins the suspension of the civil action until the criminal action is terminated. Such

was granted.
 HEIRS OF PEDRO TAYAG, SR VS. HONORABLE
FERNANDO S. ALCANTARA, PHILIPPINE RABBIT BUS
LINES, INC. & ROMEO VILLA Y CUNANAN
G.R. NO. L-50959 JULY 23, 1980

• FACTS:
• On October 25, 1977, the respondent Judge in the criminal case acquitted Villa of the crime of homicide on

the ground of reasonable doubt. After that, private respondents once again filed an MD on the civil action on

the ground that the petitioners have no cause of action against them, the driver of the bus having been

acquitted in the criminal action. Petitioners opposed and claimed however that their cause of action is not

based on crime but on quasi-delict.

• The MD was granted. Petitioners filed for MR but was denied. Hence, present petition for certiorari, to annul

and set aside the order of respondent Judge dated April 13, 1977, claiming that the respondent Judge acted

without or in excess of his jurisdiction and/or with grave abuse of discretion in issuing the disputed order, and

that there is no plain, speedy and adequate remedy in the ordinary course of law except thru the present

petition.
 ISSUE: WON RESPONDENT JUDGE ACTED WITHOUT OR IN
EXCESS OF HIS JURISDICTION AND/OR WITH GRAVE
ABUSE OF DISCRETION IN DISMISSING CIVIL CASE

• HELD:
Yes.
• Because in the case at bar, the allegations of the complaint clearly show that
petitioners' cause of action was based upon a quasi delict. Aside from the facts
established, the complaint alleged that Villa drove in faster and greater speed than
what was reasonable and proper and in a grossly negligent, careless, reckless and
imprudent manner, without due regards to injuries to persons and damage to
properties and in violation of traffic rules and regulations and that defendant
Philippine Rabbit Bus Lines, Inc. has failed to exercise the diligence of a good father
of a family in the selection and supervision of its employees.
• HELD:
• All the essential averments for a quasi delictual action are present, namely: (1) an act
or omission constituting fault or negligence on the part of private respondent; (2)
damage caused by the said act or omission; (3) direct causal relation between the
damage and the act or omission; and (4) no pre-existing contractual relation
between the parties.

• A separate civil action lies against the offender in a criminal act, whether or not he is
criminally prosecuted and found guilty or acquitted, provided that the offended
party is not allowed, if he is actually charged also criminally, to recover damages on
both scores, and would be entitled in such eventuality only to the bigger award of
the two, assuming the awards made in the two cases vary.
• HELD:
• In other words, the extinction of civil liability referred to in Par. (e), Section 3, Rule III,
refers exclusively to civil liability founded on Article 100 of the Revised Penal Code,
whereas the civil liability for the same act considered as a quasi-delict only and not
as a crime is not extinguished even by a declaration in the criminal case that the
criminal act charged has not happened or has not been committed by the accused.
Briefly stated, We here hold, in reiteration of Garcia that culpa aquiliana includes
voluntary and negligent acts which may be punishable by law. (Elcano vs. Hill)

• Thus, the petitioners' cause of action being based on a quasi-delict, the acquittal of
the driver, private respondent Romeo Villa, of the crime charged in Criminal Case No.
836 is not a bar to the prosecution of Civil Case for damages based on quasi-delict.