Butaro Yamada v. The Manila Railroad Co.

Summary

Three consolidated cases involving Japanese plaintiffs injured when their hired automobile collided with a train at a railroad crossing. The Supreme Court affirmed liability against Bachrach Garage & Taxicab Co. under Civil Code Article 1903, finding the company failed to properly supervise its drivers and had sanctioned a dangerous custom of crossing railroad tracks without adequate precautions. The Court rejected the defense that following customary practices excused negligence, holding that dangerous practices cannot ripen into protective customs. The railroad company was absolved of liability as it had given proper warning signals. The Court reduced the damage awards after finding insufficient proof for certain claimed expenses, emphasizing the requirement for best available evidence in damage claims. The case established important precedents on master liability for servant negligence in business enterprises and the limits of custom as a defense to negligence.