Title
Gabeto vs. Araneta
Case
G.R. No. 15674
Decision Date
Oct 17, 1921
Agaton Araneta stopped a carromata, but his actions were deemed too remote to proximately cause Proceso Gayetano’s fatal injuries; liability was absolved due to insufficient evidence linking his conduct to the accident.
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Case Digest (G.R. No. 15674)

Facts:

Parties Involved:

  • Plaintiff and Appellee: Consolacion Gabeto, in her own right as the widow of Proceso Gayetano and as guardian ad litem of their three children (Conchita, Rosita, and Fermin Gayetano).
  • Defendant and Appellant: Agaton Araneta.

Incident Leading to the Case:
On August 4, 1918, Proceso Gayetano and Basilio Ilano hired a carromata (a horse-drawn carriage) near Plaza Gay in Iloilo City to go to a cockpit on Calle Ledesma. The driver, Julio Pagnaya, began driving when Agaton Araneta stepped into the street, grabbed the reins, and stopped the horse, claiming he had called the carromata first. Pagnaya disputed this, stating he had not seen or heard Araneta’s call.

Sequence of Events:

  1. Araneta stopped the horse by pulling the reins, causing the bit to come out of the horse’s mouth due to the bridle’s looseness or poor condition.
  2. Pagnaya alighted to fix the bridle, pulling the horse to the curb.
  3. While Pagnaya was fixing the bridle, the horse became agitated, moved forward, and pushed Pagnaya over.
  4. The carromata struck a police telephone box on the sidewalk, frightening the horse, which then ran away at full speed.
  5. Basilio Ilano alighted safely, but Proceso Gayetano remained seated.
  6. Gayetano either jumped or fell from the carromata near the Mission Hospital, sustaining fatal injuries.

Conflict in Testimonies:

  • Plaintiff’s Witnesses (Pagnaya and Ilano): Claimed Araneta jerked the bridle, causing the bit to come out, and that Araneta later struck the horse’s nose, causing it to run away.
  • Defendant’s Witnesses: Testified that Pagnaya jerked the reins, causing the bit to come out, and that Pagnaya’s mishandling of the bridle led to the horse running away.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Proximate Cause: For liability to attach, the defendant’s act must be the proximate cause of the injury. In this case, Araneta’s act of stopping the carromata was not the proximate cause of the accident. The horse’s runaway was primarily due to the driver’s mishandling of the bridle and the horse’s reaction to being free from control.
  2. Burden of Proof: The plaintiff failed to prove that Araneta’s actions were the direct and immediate cause of the accident. The testimony of Pagnaya, which implicated Araneta, was not corroborated and was outweighed by the defendant’s evidence.
  3. Preponderance of Evidence: The evidence clearly preponderated in favor of the defendant, showing that the driver’s actions, not Araneta’s, led to the accident.


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