Case Summary (A.C. No. 13601)
Facts of the Case
• On September 13, 1952, Medina’s bus No. 30 departed Amadeo, Cavite, bound for Pasay City with approximately eighteen occupants.
• While traveling at excessive speed, a front tire burst. The bus zig-zagged some 150 meters before overturning into a roadside canal, trapping four passengers (including Juan Bataclan) inside.
• Calls for help were made; ten men arrived carrying a lighted bamboo torch. Gasoline leaking from the overturned chassis ignited, consuming the bus and the trapped passengers.
• The charred bodies of the four victims were recovered and identified; plaintiff Bataclan’s widow filed suit for compensatory, moral, exemplary damages, and attorneys’ fees.
Key Dates
• Accident: September 13, 1952, at approximately 2:00 AM
• Trial Court Decision: undisclosed date prior to appeal
• Supreme Court Decision: October 22, 1957
Applicable Law (New Civil Code of the Philippines)
• Art. 1733 – Common carriers must exercise extraordinary diligence for passenger safety and goods.
• Art. 1755 – Obliges carriers to use the utmost diligence of very cautious persons.
• Art. 1756 – Presumption of fault in case of passenger injury or death unless diligence is proven.
• Art. 1759 – Carrier liable for employee negligence, even if beyond scope of authority.
• Art. 1763 – Carrier responsible for third-party acts if proper supervision could have prevented harm.
Trial Court Findings
• The Court of First Instance held Medina liable for breach of the transportation contract.
• It found negligence by driver Conrado Saylon—excessive speed caused the tire blow-out and overturning.
• The trial court, viewing the fire as the proximate cause of death, awarded P1,000 compensatory damages, P600 attorneys’ fees, and P100 for lost merchandise.
Proximate Cause and Liability Analysis
• The Supreme Court applied the standard definition: the proximate cause is the act which, in a continuous and natural sequence, produces the injury without any efficient intervening cause.
• Overturning, not the post-accident fire, was held the proximate cause of death. Gasoline leakage and the rescuers’ use of a torch were foreseeable consequences of the overturn.
• The driver and conductor failed to warn rescuers of the gasoline spill, aggravating the carrier’s liability under Arts. 1733, 1759, and 1763.
Modification of Damages
• Considering Bataclan’s earning capacity and other factors, the award for his death was increased to P6,000 (inclusive of compensatory and moral damages).
• Attorneys’ fees were raised to P800, reflecting the services rendered at trial and on appeal.
• The P100 award for lost merchandise was affirmed
Case Syllabus (A.C. No. 13601)
Parties and Representation
- Plaintiffs‐appellants: Salud Villanueva, widow of the deceased Juan Bataclan, acting in her own name and in behalf of her five minor children (Norma, Luzviminda, Elenita, Oscar, Alfredo)
- Defendant‐appellant: Mariano Medina, owner and operator of Medina Transportation Company, common carrier
- Plaintiffs’ counsel sought compensatory, moral, and exemplary damages plus attorney’s fees totalling ₱87,150
- Decision by Justice Montemayor, concurred in by Chief Justice Paras and Associate Justices Bengzon, Padilla, Reyes A., Bautista Angelo, Labrador, Concepcion, Reyes J.B.L., Endencia, and Felix
Relevant Facts
- On September 13, 1952, shortly after midnight, bus No. 30 of Medina Transportation departed Amadeo, Cavite en route to Pasay City, driven by Conrado Saylon
- Approximately eighteen persons aboard, including driver, conductor and passengers Juan Bataclan (seated right of driver), Felipe Lara (right of Bataclan), a Visayan passenger (left of driver), and Natalia Villanueva (behind them)
- Around 2:00 AM in Imus, Cavite, a front tire burst; bus zig-zagged some 150 meters before overturning into a roadside canal and turning turtle
- Some passengers escaped; four (Bataclan, Lara, Visayan, Natalia) remained trapped inside the overturned vehicle
- Passengers and crew called for help; about half an hour later, ten men arrived carrying a burning bamboo torch
- Leaked gasoline from the chassis tank had pooled; torch ignited a fierce fire that consumed the bus and trapped occupants
- Charred bodies of the four victims, including Bataclan, were removed and identified the same day
Procedural History
- Civil suit filed in the Court of First Instance of Cavite by widow and minor children against Mariano Medina for damages arising from the death of Juan Bataclan and loss of merchandise
- Trial court awarded: ₱1,000 (damages for physical injuries to Bataclan), ₱100 (value of lost merchandise), and ₱600 (attorney’s fees)
- Both parties appealed to the Court of Appeals; appeal was endorsed to the Supreme Court due to the amount in controversy
Legal Framework
- New Civil Code o