Proximate cause in quasi-delict
Summary
Landmark Supreme Court case establishing common carrier liability principles. A Medina Transportation bus overturned after a tire blowout, trapping passengers who died when rescuers' torch ignited leaked gasoline. The trial court awarded minimal damages, viewing the fire as an intervening cause. The Supreme Court reversed, ruling the overturning was the proximate cause of death since the fire was a natural consequence of the accident. The Court applied Civil Code provisions requiring extraordinary diligence from common carriers and found the driver negligent for speeding and failing to replace old tires. Damages were increased from P1,000 to P6,000, establishing important precedent on proximate causation in transportation cases and emphasizing carrier responsibility for passenger safety through proper vehicle maintenance and operation.
Focus of dispute
Common carrier liability for passenger death resulting from bus accident and subsequent fire
Legal facts
On September 13, 1952, bus No. 30 of Medina Transportation left Amadeo, Cavite for Pasay City with 18 passengers including Juan Bataclan. At 2:00 AM, a front tire burst, causing the bus to zig-zag 150 meters before overturning into a canal. Four passengers including Bataclan were trapped inside. Rescuers arrived with a lighted torch, which ignited gasoline leaking from the overturned bus, causing a fire that killed the trapped passengers. Bataclan's widow sued for P87,150 in damages.
Judgement and reasoning
Court of First Instance of Cavite
Awarded P1,000 compensatory damages plus P600 attorney's fees and P100 for lost merchandise, finding negligence but ruling that fire, not the overturning, was the proximate cause of death, thus awarding damages for physical injuries rather than death.
Supreme Court (SC)
Reversed and increased damages to P6,000 plus P800 attorney's fees. Ruled that the overturning of the bus was the proximate cause of death, not the fire. Found the driver negligent for speeding and failing to change old tires as instructed. Held that the fire was a natural and expected consequence of the overturning, gasoline leakage, and call for help with torches in a rural area at night. Applied Civil Code provisions on common carrier extraordinary diligence and liability for employee negligence.