VDA DE BATACLAN

V.
MARIANO MEDINA
GR 12106
OCTOBER 22, 1957

Sherlyn S. Dimaampao
 TOPIC: APPROXIMATE CAUSE

FACTS:
A bus of Medina Transportation which is owned by Mariano Medina
was driven by Conrado Saylon. There were about 18 passengers
aboard, among the passengers was Bataclan who was seated beside
and at the right of the driver. At around 2 am, while the bus was
running at a high speed, one of the front tires burst and the vehicle
began to zig-zag until it fell into a canal or ditch on the right side of
the road and turned turtle. The bus was overturned. Most of the
passengers on board were able to get out of the bus however there
were 4 passengers, and the one seating near the driver's seat was
unable to get out immediately.
There is no evidence to show an attempt by any passenger or even
the bus driver/conductor to rescue or pull out the 4 remaining
passengers although calls for help were made in the houses nearby
the accident.
After an hour, about ten men answered the call for help, one of them
carried a bamboo torch fueled with petroleum. As the men
approached the bus, a fire was started because as the bus overturned,
the gas leaked over the body of the bus, and the ground around it.
The torch brought by the men, set the bus on fire.

VDA DE BATACLAN V MEDINA

 VDA DE BATACLAN V MEDINA

FACTS:
COURT OF FIRST INSTANCE COURT OF APPEALS

Lower court was of the opinion Endorsed the appeal to the

that the proximate cause of the Supreme Court because of the
death of Bataclan was not the value involved in the claim in
overturning of the bus, but the complaint which is
rather, the fire that burned the amounting to P87, 150.
bus, including himself and his
co-passengers who were unable
to leave it; that at the time the
fire started, Bataclan, though he
must have suffered physical
injuries, perhaps serious, was
still alive, and so damages were
awarded, not for his death, but
for the physical injuries
suffered by him.
 VDA DE BATACLAN V MEDINA

ISSUE
Whether or not the proximate cause of the death of
Bataclan et al was their burning was because of the
torches which ignited the gasoline.
 VDA DE BATACLAN V MEDINA

HELD

NO. The Court ruled that the approximate cause of their death was the
overturning of the bus.

The proximate cause was the overturning of the bus, this for the
reason that when the vehicle turned not only on its side but completely
on its back, the leaking of the gasoline from the tank was not
unnatural or unexpected; that the coming of the men with a lighted
torch was in response to the call for help, made not only by the
passengers, but most probably, by the driver and the conductor
themselves, and that because it was dark (about 2:30 in the morning),
the rescuers had to carry a light with them, and coming as they did
from a rural area where lanterns and flashlights were not available;
and what was more natural than that said rescuers should innocently
approach the vehicle to extend the aid and effect the rescue requested
from them.
 VDA DE BATACLAN V MEDINA

Definition of proximate cause:

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.

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.

VOLUME 38, PAGES 695-696 OF AMERICAN

JURISPRUDENCE,
 VDA DE BATACLAN V MEDINA

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