Manila Electric Co. vs. Remonquillo

Facts:

On August 22, 1950, Efren Magno went to the three-story house of his stepbrother Antonio Penaloza on Rodriguez Lanuza Street, Manila, to repair a leaking “media agua” located just below a third-story window. While standing on the media agua he received from his son, through that window, a 3' × 6' galvanized iron sheet to cover the leak; turning around while holding the sheet, its lower end contacted an exposed Manila Electric Company wire strung parallel to the media agua, causing Magno’s electrocution and death. His widow and children sued Manila Electric Company for damages.

At trial the court rendered judgment for the plaintiffs, awarding P10,000 compensatory damages, P784 actual damages, P2,000 moral and exemplary damages, and P3,000 attorney’s fees, plus costs. On appeal the Court of Appeals (Second Division) affirmed but reduced attorney’s fees to P1,000 with costs. The electric company appealed that decision to the Supreme Court.

The Court of Appeals had made detailed findings: the wire was an exposed, uninsulated primary wire carrying about 3,600 volts and had been installed two years before the house was built; during construction a carpenter’s wood contacted the wire producing sparks, and the company had moved one end of the wire after complaint but left the other; ocular inspection showed the distance from the wire to the edge of the media agua to be about 30 inches while a City of Manila regulation required at least three feet; the house owner had built the media agua wider than his permit allowed, thereby reducing the clearance; nevertheless the owner later obtained a final permit for occupancy. The Court of Appeals held the company negligent, reasoning that mere compliance with regulations did not satisfy the full scope of due diligence and that other precautions might have been warranted, and it relied on Astudillo v. Manila Electric Co., 55 Phil. 427.

The Supreme Court reviewed the record, considered the company’s unrefuted contention that practical insulation of the 3,600-volt primary wire was not commercially feasible, and analyzed causation. The Court concluded that the house owner’s illegal enlargement of the media agua (despite subsequent final occupancy approval) and Magno’s own reckless act in swinging the long i...(Pro-only)

Issues:

• Was Manila Electric Company negligent and liable for the death of Efren Magno?
• Was the Company’s alleged negligence the proximate and principal cause of Magno’s death, or was Magno’s own act the intervening proximate cause that pr...(Pro-only)

Ruling:

• (Pro-only)

Ratio:

• (Pro-only)

Doctrine:

• (Pro-only)