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It appears that, whether from a common law or

civil law perspective, the four elements of a tort


or a quasi-delict generally are: (1) duty; (2)
breach; (3) proximate cause; and (4) damage or
injury. Indeed, in his concurring opinion in Alano
v. Magud-Logmao,1 Justice Leonen enumerated
the four essential elements of a quasi-delict as:
(1) duty; (2) breach; (3) injury; and (4) proximate
causation.

1
GR No. 175540, April 7, 2014

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