Case Digest (A.C. No. 9094) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Salud Villanueva Vda. de Bataclan et al. v. Mariano Medina, decided October 22, 1957, bus No. 30 of Medina Transportation, under certificate of public convenience and driven by Conrado Saylon, departed Amadeo, Cavite shortly after midnight of September 13, 1952, bound for Pasay City with eighteen passengers aboard. Seated beside the driver was Juan Bataclan, with Felipe Lara to his right, a Visayan passenger on the left, and Natalia Villanueva directly behind them. At about 2:00 a.m., within Imus, Cavite, a front tire burst; the bus zig-zagged some 150 meters, plunged into a roadside canal, and turned turtle. While most passengers escaped, the four in front and Natalia Villanueva remained trapped. Calls for help summoned ten men bearing a lighted bamboo torch; gasoline, leaking from the overturned chassis, ignited, and the bus was consumed by fire, burning to death the four trapped individuals. Bataclan’s charred body was identified the same day. His widow, Salud Villanueva V Case Digest (A.C. No. 9094) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Accident and Overturning
- On September 13, 1952 at about 2:00 AM, Medina Transportation’s bus No. 30, driven by Conrado Saylon, was traveling from Amadeo, Cavite to Pasay City.
- Within Imus, Cavite, a front tire burst; the bus zig-zagged roughly 150 m, plunged into a roadside canal, and turned turtle.
- Passengers and Fire
- Eighteen persons were aboard, including Juan Bataclan (seated beside driver), Felipe Lara, a Visayan passenger, and Natalia Villanueva behind them. Four (Bataclan, Lara, the Visayan, Villanueva) were trapped.
- Passengers called for help. About thirty minutes later, ten men came with a bamboo torch; leaking gasoline ignited, consuming the bus and the trapped occupants.
- Procedural History
- Juan Bataclan’s widow, Salud Villanueva Vda. de Bataclan, on her own behalf and that of five minor children, sued owner-operator Mariano Medina for P87,150 (compensatory, moral, exemplary damages, attorney’s fees).
- Trial Court awarded P1,000 damages, P600 attorney’s fees, and P100 for lost merchandise.
- Both parties appealed; Supreme Court reviewed the case.
Issues:
- Carrier’s Duty and Negligence
- Whether Medina, as a common carrier, breached the duty of “extraordinary diligence” for passenger safety and cargo.
- Whether the driver’s speeding and failure to change worn tires constituted negligence.
- Proximate Cause
- Whether the proximate cause of Bataclan’s death was the bus overturning or the subsequent fire started by rescuers’ torch.
- Quantum of Relief
- Proper amount of damages (compensatory, moral, exemplary) and attorney’s fees.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)