​Jose Cangco vs Manila Railroad Co.

Facts:
On January 20, 1915, Jose Cangco was riding the train of Manila Railroad Co (MRC). He was an employee of the latter and he was given a pass so that he could ride the train for free. When he was nearing his destination at about 7pm, he arose from his seat even though the train was not at full stop. When he was about to alight from the train (which was still slightly moving) he accidentally stepped on a sack of watermelons which he failed to notice due to the fact that it was dim. This caused him to lose his balance at the door and he fell and his arm was 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 Jose 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.

HELD: 
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 without suffering injury. Jose Cangco has the vigor and agility of young manhood, and it was by no means so risky for him to get off while the train was still moving as the same act would have been in an aged or feeble person. He was also ignorant of the fact that sacks of watermelons were there as there were no appropriate warnings, and the place was dimly lit.
The Court also elucidated on the distinction between the liability of employers under Article 2180 and their liability for breach of contract [of carriage].