Salud Villanueva Vda. De Bataclan vs Mariano Medina
102 Phil 181 – Civil Law - Torts and Damages – Proximate Cause
Pass-midnight in September 1952, Juan Bataclan rode a bus owned by Mariano Medina from Cavite to Pasay. While on its way, the driver of the bus was driving fast and when he applied the brakes it cause the bus to be overturned. The driver, the conductor, and some passengers were able to free themselves from the bus except Bataclan and 3 others. The passengers called the help of the villagers and as it was dark, the villagers brought torch with them. The driver and the conductor failed to warn the would-be helpers of the fact that gasoline has spilled from the overturned bus so a huge fire ensued which engulfed the bus thereby killing the 4 passengers trapped inside. It was also found later in trial that the tires of the bus were old.
ISSUE: Whether or not the proximate cause of the death of Bataclan et al was their burning by reason of the torches which ignited the gasoline.
HELD: No. The proximate cause was the overturning of the bus which was caused by the negligence of the driver because he was speeding and also he was already advised by Medina to change the tires yet he did not. Such negligence resulted to the overturning of the bus. The torches carried by the would-be helpers are not to be blamed. It is just but natural for the villagers to respond to the call for help from the passengers and since it is a rural area which did not have flashlights, torches are the natural source of lighting. Further, the smell of gas could have been all over the place yet the driver and the conductor failed to provide warning about said fact to the villagers.
WHAT IS “PROXIMATE CAUSE”?
Proximate cause is that cause, which, in natural and continuous sequence, unbroken by any efficient intervening cause, produces the injury, and without which the result would not have occurred.
And more comprehensively, the proximate legal cause is that acting first and producing the injury, either immediately or by setting other events in motion, all constituting a natural and continuous chain of events, each having a close causal connection with its immediate predecessor, the final event in the chain immediately effecting the injury as a natural and probable result of the cause which first acted, under such circumstances that the person responsible for the first event should, as an ordinary prudent and intelligent person, have reasonable ground to expect at the moment of his act or default that an injury to some person might probably result therefrom.