Bataclan v.

Medina (1957)

FACTS:

Shortly after midnight on Sept. 13, 1952, bus no. 30 of Medina Transportation owned by Medina, the
owner defendant in the case, and driven by Saylon, its regular chauffeur, was transporting the deceased,
Bataclan, along with 17 other passengers including the driver and the conductor, from Amadeo, Cavite to
Pasay City. At around 2 in the morning, a front tire burst and the bus zigzagged into a ditch in the area of
Imus, Cavite. While the rest of the passengers managed to escape, 4 passengers, Bataclan included, were
trapped inside and could not get out. Thirty minutes later, upon cries of help from the passengers, 10 men
arrived from the nearby neighborhood, bringing with them a lit torch. Upon approaching the
bus, the bus burst into flame, for apparently gasoline had leaked out when the bus had turned turtle, and
soaked the bus and the area around it. The 4 passengers trapped inside were burned to death. It was later
established that the bus was speeding at the time the tire burst, and besides this that the tires were old
and the driver had previously been instructed to replace them but had failed to do so. The lower court
only awarded damages against the defendant based on the physical injuries sustained by Bataclan before
the bus caught fire, in the belief that the proximate cause of death was not the overturning of the bus but
rather the fire that burned the bus.

ISSUE: What is the proximate cause of the death of Bataclan and the other trapped passengers?

RATIO:

The SC cites this passage from American jurisprudence, which states: “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.' And more comprehensively, 'the proximate legal cause is that
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.”

It was only a natural consequence that in that rural area the people living there would use a torch as a
source of light and would innocently approach the overturned bus to see how they could help. The leaking
of the gasoline is also a natural result of the overturning of the bus. And so the overturning of the bus,
which is due to the negligence of the driver as demonstrated by his speeding and lack of care for the
vehicle’s roadworthy condition with regard to the state of the tires, is still the proximate cause of the
deaths of the trapped passengers. In fact, the bus bursting into flame can also be attributed to the
negligence of the carrier through its agents, the driver and the conductor, to whom it did not occur that
gasoline may very well have leaked out of the bus, and so could have warned those bearing the torch not
to get too close.