Florentina A. Guilatco v. City of Dagupan

Summary

This Supreme Court case established municipal liability for damages from defective public infrastructure under Article 2189 of the Civil Code. Florentina Guilatco, a court interpreter, suffered serious leg fractures after falling into an uncovered manhole on a Dagupan City sidewalk. While the Court of Appeals reversed the trial court's damage award, finding no city liability since Perez Boulevard was a national road, the Supreme Court reinstated liability, ruling that cities are liable when they exercise control or supervision over public works regardless of ownership. The city's liability arose through its City Engineer's charter duties to supervise drainage systems and public works. The Court reduced excessive damage awards while affirming the principle that local governments must maintain safe public infrastructure, awarding modified damages totaling approximately P41,000 for this preventable accident.