Case 1
LRTA v. Navidad, G.R. No. 145804, Feb. 6, 2003
In this case, LRTA is liable for breach of contractual duty (culpa contractual) as
provided by Article 2180 of the Civil Code of the Philippines, “xxx the owners and
managers of an establishment or enterprise are likewise responsible for damages
caused by their employees in the service of the branches in which the latter are
employed or on the occasion of their functions.”
There has been a contract between Nicanor Navidad and the LRTA upon payment of
the former’s fare for the services of the LRTA. Thus, the obligation arises from the
contract between Navidad and LRTA (Article 1159).
Case 2
Saludaga v. FEU, G.R. No. 179337, April 30, 2008
In this case, FEU and Edilberto de Jesus in his capacity as President of FEU, are liable
for culpa contractual. FEU as a learning institution is mandated or obliged to impart
knowledge and equip its students. At the same time, FEU is obliged to ensure and
take adequate steps to maintain peace and order within the campus. In culpa
contractual, the mere proof of the existence of the contract between Saludaga and
FEU, and the failure of the latter of its compliance justify, prima facie, a corresponding
right of relief. Thus, when the petitioner was shot inside the campus by the security
guard, who was hired to maintain peace and secure the premises, there is prima facie
showing that the respondents failed to comply with its obligation to provide a safe and
secure environment.
Article 1170 of the Civil Code provides that those who are negligent in the performance
of their obligations are liable for damages. Accordingly, for breach of contract due to
negligence in providing a safe learning environment, respondent FEU is liable to
petitioner for damages. It is essential in the award of damages that the claimant must
have satisfactorily proven during the trial the existence of the factual basis of the
damages and its causal connection to defendant's acts.