City of Manila vs. Genaro N.

Teotico and CA
G.R. No. L-23052. 29 January 1968.

FACTS: In January 1958, at about 8pm, Genaro Teotico was about to board a jeepney in P.
Burgos, Manila when he fell into an uncovered manhole. This caused injuries upon him.
Thereafter he sued for damages under Article 2189 of the Civil Code the City of Manila, the
mayor, the city engineer, the city health officer, the city treasurer, and the chief of police. CFI
Manila ruled against Teotico. The CA, on appeal, ruled that the City of Manila should pay
damages to Teotico. The City of Manila assailed the decision of the CA on the ground that the
charter of Manila states that it shall not be liable for damages caused by the negligence of the
city officers in enforcing the charter; that the charter is a special law and shall prevail over the
Civil Code which is a general law; and that the accident happened in national highway.

ISSUE: Whether or not the City of Manila is liable in the case at bar.

HELD: Yes. It is true that in case of conflict, a special law prevails over a general law; that the
charter of Manila is a special law and that the Civil Code is a general law. However, looking at
the particular provisions of each law concerned, the provision of the Manila Charter exempting it
from liability caused by the negligence of its officers is a general law in the sense that it exempts
the city from negligence of its officers in general. There is no particular exemption but merely a
general exemption. On the other hand, Article 2189 of the Civil Code provides a particular
prescription to the effect that it makes provinces, cities, and municipalities liable for the damages
caused to a certain person by reason of the defective condition of roads, streets, bridges,
public buildings, and other-public works under their control or supervision.
The allegation that the incident happened in a national highway was only raised for the first time
in the Citys motion for reconsideration in the Court of Appeals, hence it cannot be given due
weight. At any rate, even though it is a national highway, the law contemplates that regardless if
whether or not the road is national, provincial, city, or municipal, so long as it is under the Citys
control and supervision, it shall be responsible for damages by reason of the defective conditions
thereof. In the case at bar, the City admitted they have control and supervision over the road
where Teotico fell when the City alleged that it has been doing constant and regular inspection of
the citys roads, P. Burgos included.

De Joya v. Lantin

Case No. 31
G.R. No. L-24037 (April 27, 1967)
FACTS:
Respondent Francindy Commercial purchased bales of textile from Cebu
Company Ernerose Commercial. However, the Bureau of Customs discovered that
the goods to be delivered by Ernerose were different from those declared. Customs
took custody of the shipment.
Francindy Commercial filed a petition in the Court of First Instance for
Customs to release the goods. Francindy insisted that the CFI had jurisdiction on
the basis of the Judiciary Act and not the Bureau of Customs. RA 1937 and 1125, on
the other hand, vest exclusive jurisdiction over seizure and forfeiture proceedings to
the Bureau of Customs.
ISSUE:
Who has jurisdiction over the shipment.

HELD:
The Bureau of Customs does. RA 1937 and 1125 are special laws, whereas the
Judiciary Act is a general law. In case of conflict, special laws prevail over general
ones.