Torts; Quasi-delict; Defenses; Plaintiff’s negligence as the proximate cause

Manila Electric v. Remoquillo

GR No. L-8328 (1956)

Facts:

1. Efren Magno was tasked to repair the media agua on the house of his stepbrother
because of a leaking condition. The repair needed a metal sheet to cover the leaking
portion. Magno was standing on the media agua, and thru a window, his son handed
over to him a GI sheet.
2. Upon taking the sheet he turned around and the lower portion of the sheet touched
the live wire of Manila Electric Co. which was strung parallel to the media agua.
Magno was electrocuted which led to his death.
3. When the heirs of Magno sued Manila Electric for damages, Manila Electric raised
the defense that it was Magno’s own negligence that caused his death.
4. Manila Electric argued that considering the facts of the case, their live wire could not
be said to be the proximate cause of Magno’s death.

Issue:

Whether or not Manila Electric could be held liable for negligence

Ruling:

No. The live wires were not the proximate cause of Magno’s death. It was just a remote
cause. The SC ruled that a prior and remote cause cannot be made basis of an action if such
remote cause did nothing more than furnish the condition or give rise to the occasion by
which the injury was made possible. If no danger