Primary Holding

The Supreme Court held that an action for damages can be maintained in Philippine jurisdiction for the death of a person by wrongful act, and that in cases involving the death of a minor child, the law presumes pecuniary loss to the parent without need for specific proof of actual earnings or support.

Background

In this landmark case from 1918, an automobile accident occurred on the morning of March 5, 1916, at the intersection of Solana and Real Streets in Manila. Rafael Moreta was driving his automobile from the southern part of Solana Street when he encountered other vehicles at Real Street. After this encounter, instead of proceeding cautiously, he continued at high speed without sounding his horn. As he entered Solana Street, his vehicle struck and fatally injured Salvador Bona, a child between 8 and 9 years old, who was crossing from the right sidewalk to the left. The impact was so severe that even after hitting the child, the automobile continued moving for about two meters. The victim's mother, Simona Manzanares, a poor washerwoman, filed a civil case seeking P5,000 in damages. The Court of First Instance awarded her P1,000 as indemnity, which Moreta appealed after his motion for a new trial was denied. The case reached the Supreme Court through a bill of exceptions, where it became a pivotal decision establishing important principles about damage compensation in cases involving wrongful death, particularly concerning minor children.

Facts

• 1. An 8-9 year old child named Salvador Bona was run over by an automobile driven by defendant Moreta
• 2. The accident occurred on Solana Street on the morning of March 5, 1916
• 3. The automobile was running at high speed when entering Solana Street from Real Street
• 4. After running over the child, the automobile still moved about 2 meters
• 5. The defendant had not blown the horn before the accident
• 6. The mother of the deceased child was a poor washerwoman
• 7. The mother sought damages of P5,000, but was awarded P1,000 by the trial court

Arguments of the Petitioners

• 1. The defendant was negligent in operating the vehicle at high speed
• 2. The defendant failed to take necessary precautions when crossing streets
• 3. The defendant failed to blow the horn to warn pedestrians

Arguments of the Respondents

• 1. Defendant filed a motion for a new trial (which was overruled)
• 2. Appealed the judgment claiming errors in the trial court's decision
• 3. Contested the amount of damages awarded

Issues

• 1. Whether an action for damages can be maintained for death by wrongful act
• 2. Whether specific proof of pecuniary loss is required in cases involving death of a minor child
• 3. Whether the amount of P1,000 as damages was proper

Ruling

• 1. The Court affirmed the trial court's decision awarding P1,000 in damages
• 2. The defendant was clearly negligent in operating the vehicle
• 3. The accident could have been avoided if proper precautions were taken
• 4. In cases involving death of a minor child, specific proof of pecuniary loss is not required
• 5. The law presumes damage to the parent from the fact of death
• 6. The amount awarded was neither excessive nor inadequate

Doctrines

• 1. Doctrine of Presumed Damages - In cases involving death of a minor child, the law presumes pecuniary loss to the parent without need for specific proof
• 2. Doctrine of Reasonable Compensation - The value of human life cannot be exactly estimated in money, but courts must provide reasonable compensation within human powers
• 3. Doctrine of Negligence - A person who causes damage to another through fault or negligence is obliged to repair the damage

Precedents Cited

• 1. Burvant vs. Wolfe [1910], 126 La., 787 - Cited as corroborative authority for awarding damages
• 2. Mobile Life Ins. Co. vs. Brame [1878], 95 U.S., 754 - Discussed common law principle regarding civil actions for death
• 3. Chicago vs. Scholten [1874], 75 III., 468 - Referenced for presumption of pecuniary loss in parent-child relationships

Statutory and Constitutional Provisions

• 1. Article 1902 of the Civil Code - Established obligation to repair damage caused by fault or negligence
• 2. Article 1803 of the Civil Code (as cited in Porto Rico cases) - Regarding obligation to repair damage caused by fault or negligence