Corliss v Manila Railroad

G.R. No. L-21291

FACTS: On the evening of February 21, 1957, at the railroad crossing in Balibago, Pampanga in
front of Clark Air Force Base, the husband of Preciolia, Ralph Corliss, an air police, was driving
a jeep, together with a P.C. soldier, to the Clark base to return the jeep. A train was passing by
and blew it´s siren. Plaintiff´s husband slowed down his jeep but did not make a full stop. The
jeep collided with the locomotive engine of the train Ralph died of serious burns in the base
hospital the next day.

Preciolita filed a complaint for recovery of damages against Manila Railroad. The lower court,
however, ruled in favor of Manila Railroad. The lower court opined that Ralph was a victim of
his own wrongdoing and miscalculation when he took the risk and attempted to beat the
oncoming locomotive and aiming to reach the other side of the railroad crossing before said
locomotive could pass the jeep by. Hence, the present case.

ISSUE: Whether there is negligence on the part of Manila Railroad

RULING:
NO, the Court ruled that the present action is predicated on negligence, the Civil Code making
clear that whoever by act or omission causes damage to another, there being negligence, is under
obligation to pay for the damage done.

The Court cited the cases of U.S. v. Juanillo and U.S. v. Barias in defining what is negligence:
“The failure to observe for the protection of the interests of another person that degree of care,
precaution and vigilance which the circumstance justly demand whereby such other person
suffers injury.”

In determining the presence of negligence, the court explained that every case must be dependent
on its facts. The circumstances indicative of lack of due care must be judged in the light of what
could reasonably be expected of the parties. If the objective standard of prudence be met, then
negligence is ruled out.

It is improper to impute negligence on Manila Railroad since material facts show that it is clear
that Ralph Corliss was so sufficiently warned in advance (the lower court pointed out that
moments before the collision, Teodorico Capili who was manning the locomotive which was
then 300 meters away from exact point of accident, blew the siren and repeated it in compliance
with the regulation) of the oncoming train that it was incumbent upon him to avoid a possible
accident — and this consisted simply in stopping his vehicle before the crossing and allowing the
train to move on.

A prudent man under similar circumstances would have acted in such a manner, but
unfortunately, Ralph had failed to do so despite him having been crossing the checkpoint
frequently, if not daily and must have been aware that locomotive engines and trains usually pass
at that particular crossing where the accident had taken place.