Title
Cagayan II Electric Cooperative, Inc. vs. Rapa
Case
G.R. No. 199886
Decision Date
Dec 3, 2014
A motorcycle accident caused by a dangling electric wire led to a death and injuries. The Supreme Court ruled no negligence by CAGELCO II, attributing fault to the driver’s over-speeding and imprudence, and dismissed claims due to lack of legal standing by the common-law wife.
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Case Digest (G.R. No. 199886)

Facts:

Background of the Case:

  • On October 31, 1998, around 9:00 p.m., a motorcycle carrying three passengers—Camilo Tangonan (driver), Allan Rapanan, and Erwin Coloma—met with an accident along the National Highway of Maddalero, Buguey, Cagayan. Camilo died, while Rapanan and Coloma suffered injuries.
  • Respondents Allan Rapanan and Mary Gine Tangonan (Camilo’s common-law wife) filed a complaint for damages against petitioner Cagayan II Electric Cooperative, Inc. (CAGELCO II) on March 29, 2000, before the Regional Trial Court (RTC) of Aparri, Cagayan.
  • They alleged that the accident occurred when the motorcycle was struck and electrocuted by a live tension wire dangling from an electric post owned by CAGELCO II. They claimed that CAGELCO II was negligent in failing to repair or replace the wire despite being informed of its dangerous condition.

Claims of the Respondents:

  • Mary Gine Tangonan sought damages for Camilo’s death, including:
    • P50,000 civil indemnity
    • P25,000 burial expenses
    • P1,584,000 for loss of earning capacity
    • P100,000 for moral and exemplary damages
  • Allan Rapanan sought:
    • P10,000 for medical treatment
    • P50,000 for moral and exemplary damages
  • Both prayed for 30% of the total award as attorney’s fees.

Defense of the Petitioner:

  • CAGELCO II argued that the dangling wire was caused by typhoons Iliang and Loleng, which were fortuitous events. They claimed to have cleared the area of fallen poles and wires immediately after the typhoons.
  • They also contended that the proximate cause of the accident was Camilo’s negligence in driving the motorcycle at high speed and overloading it with passengers.

Trial Court Proceedings:

  • The RTC ruled in favor of CAGELCO II, dismissing the complaint. It held that Camilo’s negligence was the proximate cause of the accident and that Mary Gine, as a common-law wife, had no legal standing to sue for damages.

Court of Appeals Decision:

  • The CA reversed the RTC, holding CAGELCO II liable for quasi-delict. It awarded damages to Rapanan and Camilo’s legal heirs, apportioning 50% liability to CAGELCO II due to its negligence in maintaining its facilities.

Issue:

  1. Negligence of Petitioner: Was CAGELCO II’s negligence in maintaining its facilities the proximate cause of Camilo’s death and Rapanan’s injuries?
  2. Award of Damages: Should damages be awarded to Camilo’s heirs even if they were not impleaded in the case?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court ruled that CAGELCO II was not negligent and that the accident was caused by Camilo’s over-speeding and imprudence. It also held that Mary Gine Tangonan had no legal standing to sue for damages. The RTC’s decision dismissing the complaint was reinstated.


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