PEÑA, TABITHA ERLINDA MA. PAS A.

CASE DIGEST

BATACLAN vs. MEDINA

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

FACTS:

1. On the wee hours of September 13, 1952, a bus registered under the Medina
Transportation owned by Mariano Medina was being driven to Pasay City from
Amadeo, Cavite by Conrado Saylon. Aboard were Saylon, the conductor and eighteen
passengers when it was met with an accident.
2. At around 2 o’clock that same morning, as the bus was running along a rural town in
Imus, Cavite, one of its front tires burst, causing it to zigzag, fall into a canal and turn
turtle.
3. Although most of the passengers managed to get out of the overturned bus, four were
unfortunately trapped inside, namely: Juan Bataclan, Felipe Lara, Natalia Villanueva,
and a certain man identified only as “Visaya.”
4. Shortly thereafter, 10 men came to the rescue—one of whom was carrying a lighted
torch. Upon approaching the overturned bus, fire ensued, engulfing the bus and
burning the trapped passengers.
5. The incident consequently led Bataclan’s wife and heirs to file a complaint against
Medina with the Court of First Instance, praying for compensatory, moral and
exemplary damages as well as attorney’s fees.
6. The trial court awarded damages to the Bataclans, ruling that there was negligence on
the part of the defendant through driver Saylon who was reported to have been driving
the bus at an uncontrollable speed, thereby disabling him to hit the brake and timely
stop the bus.
7. The plaintiffs and defendants appealed to the Court of Appeals the decision on
damages awarded; the appellate court endorsed the appeal to the Supreme Court.

ISSUE:

Whether or not the proximate cause of the death of Bataclan et al. was the fire that
burned the bus and not the overturning of said vehicle due to Saylon’s negligence

RULING:

No. A 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. As such, the proximate cause of the death of Bataclan et al. was the
overturning of the bus due to the driver’s reckless driving—Gasoline leaking from the tank of
an overturned bus was only natural and was actually to be expected. Moreover, while it may
be argued that had it not been for the fire that allegedly ensued from the torch brought by one
of the rescuers, there must have been no casualties, the rescuers would not have approached
the scene in the first place if the driver was careful enough in manning the vehicle. In
addition, the driver and conductor should have aptly prevented the fire, had they warned the
rescuer holding the torch of a probable gas leak on site.