Case Summary (G.R. No. 15674)
Background of the Case
- Consolacion Gabeto, as the widow of Proceso Gayetano and guardian ad litem for their three children, initiated a lawsuit against Agaton Araneta.
- The case was filed in the Court of First Instance of Iloilo, seeking damages for the death of Proceso Gayetano, allegedly caused by Araneta's wrongful act.
- The trial court awarded Gabeto damages amounting to P3,000, prompting Araneta to appeal the decision.
Incident Description
- On August 4, 1918, Proceso Gayetano and Basilio Ilano hired a carromata to travel to a cockpit in Iloilo.
- As the carromata began its journey, Agaton Araneta intervened by stopping the horse and claiming he had called for the vehicle first.
- The driver, Julio Pagnaya, asserted that he had not heard Araneta's call and had taken the passengers who first offered employment.
Sequence of Events Leading to the Accident
- During the confrontation, Pagnaya attempted to regain control of the horse, but the bridle became loose, causing the bit to slip from the horse's mouth.
- Pagnaya exited the carromata to fix the bridle, moving the horse to the curb.
- While Pagnaya was occupied, the horse, now free from the bit, became agitated, moved forward, and inadvertently pushed Pagnaya over.
The Runaway Horse and Fatal Outcome
- The carromata struck a police telephone box, which fell and startled the horse, prompting it to run away.
- Proceso Gayetano, who remained in the carromata, either jumped or was thrown out during the horse's flight, sustaining injuries that led to his death shortly thereafter.
Legal Analysis of Proximate Cause
- The court examined whether Araneta's actions constituted the proximate cause of Gayetano's death.
- It was determined that even if Araneta's act of stopping the horse was improper, it was too remote from the subsequent accident to be considered the legal cause of death.
- The driver, Pagnaya, had assumed control of the horse after exiting the carromata, making him primarily responsible for the animal's behavior.
Testimony and Credibility Issues
- Testimonies from Pagnaya and Ilano suggested that Araneta's actions directly led to the horse's runaway behavior.
- However, the court found inconsistencies in the...continue reading