Díaz v. San Juan Light & Transit Co.
17 P.R. Dec. 69 (1911)
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Rule of Law:
In a negligence action under Puerto Rico's Civil Code, a plaintiff may recover general damages for physical pain and mental suffering without providing specific monetary proof of loss. The court has the discretion to determine a reasonable and just compensation based on the nature and extent of the injuries proven.
Facts:
- The San Juan Light and Transit Co. operated a public trolley service in Puerto Rico.
- On October 5, 1908, Alejandro Díaz was a paying passenger on one of the company's trolleys.
- The trolley stopped at Díaz's intended destination, and he began to disembark with due care.
- While Díaz was stepping off the trolley, the motorman negligently and suddenly started the vehicle again.
- The sudden movement threw Díaz to the ground, causing him to lose consciousness and suffer severe injuries, including a fractured jaw, leg wounds that became ulcers, and various contusions.
- As a result of the accident, Díaz, a 51-year-old farmer and father of six, suffered long-term effects including facial paralysis, difficulty eating, and a nervous condition that impaired his ability to work and support his family.
Procedural Posture:
- Alejandro Díaz filed a lawsuit against the San Juan Light and Transit Co. in the District Court of San Juan, seeking $6,000 for personal injury damages.
- The defendant's demurrer, which argued the complaint failed to state a cause of action, was dismissed by the trial court.
- The defendant filed an answer denying liability and asserting that Díaz's own negligence was the proximate cause of his injuries.
- Following a trial, the District Court found in favor of the plaintiff, Díaz, and entered a judgment awarding him $2,000 in damages plus costs.
- The defendant, San Juan Light and Transit Co., appealed the judgment to the Supreme Court of Puerto Rico.
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Issue:
Does a plaintiff in a personal injury action need to provide specific monetary proof of losses, such as receipts or exact lost wages, to recover damages for physical pain and suffering?
Opinions:
Majority - del Toro, Associate Justice
No. A plaintiff is not required to provide specific monetary proof of losses to recover general damages for physical pain and suffering. The court reasoned that while Article 1803 of the Civil Code obligates a negligent party to 'repair the damage caused,' this does not limit recovery to losses that can be precisely calculated in dollars and cents. The court adopted a broader, more equitable interpretation influenced by the American common law concept of 'damages,' which includes compensation for harms like physical pain, mental suffering, and damage to reputation. Citing legal dictionaries and precedent, the court affirmed that the law can presume losses from the nature of the injury itself. Since Díaz proved he suffered significant physical and mental harm as a direct result of the defendant's negligence, it was proper for the trial court to use its discretion to assess the evidence and award a just monetary compensation for those non-pecuniary injuries.
Analysis:
This decision is significant for integrating the American common law approach to general damages into Puerto Rico's civil law framework for torts. By interpreting the Civil Code's requirement to 'repair the damage' broadly, the court established that compensation is not limited to provable economic losses. This precedent solidifies the right of personal injury victims in Puerto Rico to receive monetary awards for non-economic harms like pain and suffering, empowering trial courts to use their discretion in valuing such damages based on the evidence of the injury's severity and impact.
