Cangco vs Manila Railroad Co HELD:

FACTS: Yes. Alighting from a moving train while it is slowing down is a

common practice and a lot of people are doing so every day
On January 20, 1915, Cangco was riding the train of Manila
without suffering injury. Cangco has the vigor and agility of
Railroad Co (MRC). He was an employee of the latter and he
young manhood, and it was by no means so risky for him to get
was given a pass so that he could ride the train for free. When
off while the train was yet moving as the same act would have
he was nearing his destination at about 7pm, he arose from his
been in an aged or feeble person. He was also ignorant of the
seat even though the train was not at full stop. When he was
fact that sacks of watermelons were there as there were no
about to alight from the train (which was still slightly moving)
appropriate warnings and the place was dimly lit.
he accidentally stepped on a sack of watermelons which he
The Court also elucidated on the distinction between the liability
failed to notice due to the fact that it was dim. This caused him
of employers under Article 2180 and their liability for breach of
to lose his balance at the door and he fell and his arm was
contract [of carriage]:
crushed by the train and he suffered other serious injuries. He
was dragged a few meters more as the train slowed down.

It was established that the employees of MRC were negligent in

piling the sacks of watermelons. MRC raised as a defense the
fact that Cangco was also negligent as he failed to exercise
diligence in alighting from the train as he did not wait for it to
stop.

ISSUE: Whether or not Manila Railroad Co is liable for

damages.