​TORIO v. FONTANILLA

ISSUE:  Whether or not the Municipality of Malasiqui may be held liable. 

FACTS:  On October 21, 1978, the municipal council of Malasiqui, Pangasinan passed 2 resolutions: one for management of the town fiesta celebration and the other for the creation of the Malasiqui Town Fiesta Executive Committee. The Executive Committee, in turn, organized a sub-committee on entertainment and stage with Jose Macaraeg as Chairman. The council appropriated the amount of P100.00 for the construction of 2 stages, one for the "zarzuela" and another for the cancionan. While the zarzuela was being held, the stage collapsed. Vicente Fontanilla was pinned underneath and died in the afternoon of the following day. Fontanilla’s heirs filed a complaint for damages with the CFI of Manila. The defendants were the municipality, the municipal council and the municipal council members. In its Answer, defendant municipality argued that as a legally and duly organized public corporation it performs sovereign functions and the holding of a town fiesta was an exercise of its governmental functions from which no liability can arise to answer for the negligence of any of its agents. 

DECISION:  Yes. The Municipality of Malasiqui was held liable. 

​RATIO DECIDENDI:  Under the doctrine of respondent superior, petitioner-municipality is liable for damages for the death of Vicente Fontanilla because the accident was attributable to the negligence of the municipality's officers, employees, or agents.