#9

SALUD VILLANUEVA VDA. DE BATACLAN vs. MARIANO MEDINA

G.R. No. L-10126 October 22, 1957

FACTS: At around 2am, a Medina Transportation bus was on its way to Pasay from Cavite, when one of the front tire burst and the vehicle
began to zigzag until it fell into a ditch on the right side of the road and turned turtle. Some of the passengers were able to pull themselves
out of the wreck and was able to leave the bus. Some of them even tried to help their fellow passengers but some passengers were pinned
and could not be pulled out from the bus. At this time, some passengers clambered up to the road and shouted for help.

About half an hour, people in the nearby village responded. They went to the wreckage and brought lighted torch with them. The
torch was made of bamboo with a wick on the upper end fueled by petroleum. As the men approached the overturned bus, fire consumed
the bus almost immediately burning alive the four passengers trapped inside. One of whom is Juan Bataclan. It appears that the gasoline
spilled from the bus’ tank and the gasoline caught fire from the torch.

The heirs of Bataclan sued the owner of Medina Transport for damages. The owner of the bus company denies liability saying that
the proximate cause of the unfortunate incident was the fire caused by the torch carried by the village people and not the overturning of the
bus.

ISSUE: Whether or not the proximate cause of Bataclan’s death was the overturning of the bus hence making the bus owner liable for
damages.

HELD: Proximate cause is defined as 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. In other words, it is that event that produced a
continuous natural chain of events, which led to the injury.

It was ruled that the proximate cause of Bataclan’s death was the overturning of the bus, which was the result of the bus driver’s
negligence. Since the driver was informed and was instructed to change the tires immediately as they were already old, but he did not
follow said instructions. Had the driver followed the instructions, the tires would not have burst even if he was driving a bit fast. Also, it is
only natural that from that state of the bus, gasoline from its tank would leak and it would have soaked the surrounding area, which would
have been smelt. Despite this, the driver and the conductor failed to warn the rescuers who carried with them a torch. As for the torch due
to the accident happening at around 2:30 in the morning it is only natural for the rescuers to carry a light with them and coming from a rural
area lanterns and flashlights were not readily available. Hence, the bus owner is liable for damages.