Case Summary (G.R. No. L-8328)
Factual Background
Efren Magno was repairing a leaking "media agua" (a sloping roof projection) on the third story of Antonio Penaloza's house. While standing on this structure, Magno received a 3’ x 6’ galvanized iron sheet from his son to cover the leak. Upon turning around, the iron sheet came into contact with a 3,600-volt uninsulated Manila Electric Company primary wire located approximately 2.5 feet from the edge of the "media agua," resulting in Magno’s electrocution and death.
Regulatory and Structural Conditions
The City of Manila regulations mandated a minimum clearance of 3 feet from all wires to buildings. The electric wire had been installed two years prior to the construction of the house and originally met this requirement from the side of the house. However, during construction, the "media agua" built by the owner exceeded permitted dimensions by 17.5 inches beyond the authorized 1 meter (39⅜ inches), thereby reducing the clearance from the wire to 2.5 feet—less than the prescribed minimum.
Procedural History and Initial Judgments
Magno’s widow and children filed for damages against Manila Electric Company. The trial court awarded various damages totaling P15,784, which the Court of Appeals affirmed with a reduction in attorney’s fees. The Electric Company instituted the appeal to the Supreme Court.
Findings on Negligence and Liability
The Court of Appeals found the company negligent despite wire installation conforming to city ordinances, emphasizing that mere compliance with regulations does not fulfill the duty of due diligence nor negate the necessity for additional protective measures. They considered negligence is not merely a matter of inches regarding wire clearance but rejected the company’s argument about measuring distance from the "media agua." However, the Court refrained from specifying what additional precautions should have been implemented.
Supreme Court Ruling on Responsibility
The Supreme Court reversed the Court of Appeals ruling, concluding that Magno’s death was primarily caused by his own negligence and secondarily due to the illegal extension of the "media agua." The Court held that:
- The electric company complied with all regulations and cannot be expected to inspect or take corrective action for illegal modifications by third parties.
- The discovery of the illegal construction and its approval by municipal authorities was beyond the company’s control.
- The exposure of primary, high-voltage wires without insulation was unavoidable given the technological and economic realities at the time.
- The distance of 7 feet between the wires and the main house structure satisfied the city ordinance.
- Although the proximity of the wires to the illegally constructed "media agua" was a contributing factor, it was not the proximate cause.
Consideration of Proximate Cause and Contributory Negligence
The Court emphasized the legal principle distinguishing proximate and remote causes, explaining that:
- The electric wire was a remote cause, furnishing a condition but not directly causing injury.
- Magno’s recklessness—turning without caution while swinging a long iron sheet near live wires—was the proximate and principal cause of death.
- Precedents, such as the Taylor case, support denial of recovery where the plaintiff’s own acts constitute the principal cause despite initial negligence by a third party.
Distinction from Previous Cases
The Court differentiated this case from Astudillo v. Manila Electric Co., where negligence was clear due to wires being accessible in a public place frequented by un
...continue readingCase Syllabus (G.R. No. L-8328)
Facts and Incident Leading to the Lawsuit
- On August 22, 1950, Efren Magno went to repair a leaking “media agua” on the third story of Antonio Penaloza’s house, located on Rodriguez Lanuza street, Manila.
- While standing on the “media agua,” Magno received from his son a 3’ x 6’ galvanized iron sheet through the window.
- Turning around while holding the sheet, the lower end came into contact with an exposed, uninsulated Manila Electric Company electric wire running parallel and approximately two and one-half feet from the edge of the “media agua,” causing Magno’s death by electrocution.
- Magno’s widow and children filed suit against Manila Electric Company seeking damages.
Trial Court Judgment
- Trial court found Manila Electric Company liable and awarded damages as follows:
- ₱10,000 as compensatory damages.
- ₱784 as actual damages.
- ₱2,000 as moral and exemplary damages.
- ₱3,000 as attorney’s fees, plus costs.
- The Court of Appeals affirmed the judgment but reduced attorney's fees from ₱3,000 to ₱1,000.
Appeal to the Supreme Court
- Manila Electric Company appealed the Court of Appeals decision to the Supreme Court.
- The Court of Appeals’ findings of fact were considered conclusive and centered on:
- The electric wire was a 3,600-volt uninsulated, exposed primary wire installed two years before house construction.
- During house construction, the owner had complained to the Company after a piece of wood touched the wire producing sparks; the company adjusted the wire at one end but left the other end near the house.
- The distance from the electric wire to the edge of the “media agua” was only 30 inches (2½ feet).
- Manila City regulations required wires to be at least three feet from buildings.
- The rule’s intent was that the “media agua” is integral to the building, so measurement from its edge was proper.
- The house owner exceeded his permit by building the “media agua” 17½ inches wider than allowed, reducing the distance to the electric wire.
- Despite this violation, the city issued a final occupancy permit approving the illegal construction.
- The electric wire lacked insulation, unrefuted by the Company’s claim that practical and affordable insulation was unavailable.