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 20-30blasting 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 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.

In the case at bar, it is true that Manila Electric has been negligent in disposing off the caps which they
used for the powerplant, 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.

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.

“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.”