Title
Visayan Electric Co., Inc. vs. Alfeche
Case
G.R. No. 209910
Decision Date
Nov 29, 2017
A 1998 fire caused by VECO's relocated electric wires abrading M. Lhuillier's signboard led to property damage. Courts ruled VECO negligent, holding it liable for damages under quasi-delict principles.
A

Case Digest (G.R. No. 209910)

Facts:

On the night of January 6, 1998, a fire broke out at a commercial-residential area in San Fernando, Cebu, which destroyed the house and store of respondents Emilio and Gilbert Alfeche, as well as an adjacent watch repair shop owned by Emmanuel Manugas. The fire was allegedly caused by the short circuiting of electric wires that had been abraded due to their close proximity to a signboard installed by M. Lhuillier Pawnshop and Jewelry.
  • VECO, the electric distribution company, had relocated some of its posts and wires in connection with a road-widening and drainage project that commenced in late 1997. This relocation purportedly brought the wires within an unsafe eight-inch clearance from M. Lhuillier’s signboard.
  • Testimonies from both parties surfaced. Plaintiffs (the Alfeches and Manugas) established that the close contact and abrasion between the wires and the sign led to the cutting and burning of the wires, which in turn ignited the fire. Witnesses such as Emilio, his wife Mignonette, and a bystander (Rodolfo Rabor) confirmed the sequence of events.
  • VECO, however, contended that the fire was attributable to the negligence of M. Lhuillier in installing its signboard, alleging that its own posts were not relocated until after the fire occurred. In rebuttal, evidence and testimonies, particularly those of Engr. Lauronal and other municipal officials, demonstrated that the relocation of the posts occurred well before the fire, thereby causing the hazardous proximity responsible for the short circuit.
  • Both the Regional Trial Court and the Court of Appeals recognized that the immediate, proximate cause of the fire was the short circuiting resulting from the abrasion of VECO’s wires due to their intimate contact with the sign.

Issues:

  • The main issue is whether VECO’s negligence in relocating its posts and wires—that led to their dangerous proximity and subsequent contact with M. Lhuillier’s signboard—was the proximate cause of the fire that damaged the properties of the Alfeches and Manugas.
  • A sub-issue is whether the Court of Appeals was correct in reversing the trial court’s original decision that held M. Lhuillier liable, thereby shifting liability to VECO based on the evidence of the relocation of its posts ahead of the fire.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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