Bjdc Construction v. Nena E. Lanuzo

Summary

This case involves a claim for damages arising from the death of motorcycle rider Balbino Lanuzo who crashed into a barricade at BJDC Construction's highway re-blocking project. The victim's heirs alleged negligence due to inadequate lighting, while the company claimed the victim's own negligence caused the accident. The RTC dismissed the complaint, finding the victim was overtaking at high speed without a helmet when he hit a lighted barricade. The CA reversed, applying res ipsa loquitur and finding inadequate lighting. The Supreme Court reinstated the RTC decision, holding that plaintiffs failed to prove by preponderance of evidence that the company's negligence was the proximate cause. The Court concluded that the victim's own negligence - reckless overtaking and failure to wear protective gear - was the immediate and proximate cause of his death, precluding recovery under Article 2179 of the Civil Code.