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MUNICIPALITY OF SAN JUAN v. CA

FACTS:

The Metropolitan Waterworks and Sewerage System (MWSS) had a contract with KC Waterworks System Construction (KC) for the installation of water service connections. KC was responsible for conducting excavations in San Juan, Metro Manila as part of the contract. Five workers were dispatched by KC to perform the digging operations and barricades were installed to mark the area. However, while driving on the flooded Santolan Road, Priscilla Chan's car, with Assistant City Prosecutor Laura Biglang-awa as a passenger, fell into an uncovered manhole. Biglang-awa suffered a fractured arm as a result. A police officer who investigated the accident did not find any barricades at the scene. Consequently, Biglang-awa filed a complaint for damages against MWSS, the Municipality of San Juan, and other officials. The trial court found in favor of Biglang-awa, holding MWSS and the Municipality of San Juan jointly and severally liable for damages. Both parties appealed the decision to the Court of Appeals, which affirmed the trial court's ruling with modifications. The Municipality of San Juan then filed a petition for review before the Supreme Court.

ISSUES:

  1. Whether the Municipality of San Juan can be held liable for damages in this case.

  2. Whether the Metropolitan Waterworks and Sewerage System (MWSS) can be held liable for damages in this case.

RULING:

  1. The Municipality of San Juan can be held liable for damages. Both the trial court and the Court of Appeals ruled that the Municipality of San Juan is jointly and severally liable with MWSS for the damages suffered by the private respondent. The Court of Appeals affirmed the decision of the trial court, ordering the Municipality of San Juan to pay the private respondent the amounts of actual damages, moral damages, exemplary damages, and attorney’s fees. The petition is therefore denied.

  2. MWSS can also be held liable for damages. The Court of Appeals affirmed the decision of the trial court, ruling that MWSS is jointly and severally liable with the Municipality of San Juan. MWSS is ordered to pay the private respondent moral damages, exemplary damages, and attorney’s fees. The petition is therefore denied.

PRINCIPLES:

  • A municipality can be held liable for damages if there is negligence on its part that causes harm to an individual.

  • Joint and several liability may be imposed when multiple parties are concurrently responsible for the damages suffered by an individual.