Scribd
Upload
159 views2 pages

Manila Electric Co. Vs Remonquillo

Efren Magno was electrocuted while repairing a leaking media agua near an uninsulated electric wire owned by Manila Electric Company (Meralco). His family sued Meralco for damages. The court ruled that while Meralco was negligent in failing to insulate the wire, Efren's own negligence was the proximate cause of his death. As an experienced tinsmith, Efren should have taken precautions like checking for wires before swinging a long metal sheet, but failed to do so. A remote cause like Meralco's negligence is not a valid basis for legal action if a subsequent, independent act was the direct cause of injury. The court found Efren's

Uploaded by

Mav Esteban
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
159 views2 pages

Manila Electric Co. Vs Remonquillo

Efren Magno was electrocuted while repairing a leaking media agua near an uninsulated electric wire owned by Manila Electric Company (Meralco). His family sued Meralco for damages. The court ruled that while Meralco was negligent in failing to insulate the wire, Efren's own negligence was the proximate cause of his death. As an experienced tinsmith, Efren should have taken precautions like checking for wires before swinging a long metal sheet, but failed to do so. A remote cause like Meralco's negligence is not a valid basis for legal action if a subsequent, independent act was the direct cause of injury. The court found Efren's

Uploaded by

Mav Esteban
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
You are on page 1/ 2

Manila Electric Co.

v Remoquillo
GR No. L-8328, 18 May 1956
Montemayor, J.:

FACTS
Efren Magno (Efren for brevity) went to the 3-story house his stepbrother to repair a
media agua located just below the window of the third story that was said to be leaking.
Turning around after receiving a 3’x6’ galvanized iron sheet to cover the leaking
portion, the lower end of the iron sheet came into contact with the electric wire of
Manila Electric Company (Meralco for brevity), electrocuting him and thereafter lead to
his death. Such strung 2.5 feet parallel to the edge of the media agua and was
uninsulated.

His widow and children filed a suit to recover damages against the company. The trial
court and the CA ruled in their favor. Hence this petition.

ISSUE
Whether the negligence of Manila Electric Co. in the installation and maintenance of its
wires was the proximate cause of Efren’s death.

HELD
The Court ruled in the negative, Efren’s death was caused by his own negligence.
Meralco’s negligence in the installation and maintenance of its wires merely provided
the condition from which the cause of the injury arose.

A prior and remote cause cannot be made the basis of an action if such remote cause did
nothing more than furnish the condition or give rise to the occasion by which the injury
was made possible, if there intervened between such prior or remote cause and the
injury a distinct, successive, unrelated, and efficient cause of the injury, even though
such injury would not have happened but for such condition or occasion. If no danger
existed in the condition except because of the independent cause, such condition was
not the proximate cause. And if an independent negligent act or defective condition sets
into operation the circumstances which result in injury because of the prior defective
condition, such subsequent act or condition is the proximate cause.
The principal and proximate cause of the electrocution was not the electric wire,
evidently a remote cause, but rather the reckless and negligent act of Efren in turning
around and swinging the galvanized iron sheet without taking any precaution, such as
looking back toward the street and at the wire to avoid its contacting said iron sheet,
considering the latter’s length of 6 feet.

Furthermore, the Supreme Court agreed to the following arguments of Manila Electric
Company proving that it was Efren’s own negligence that caused his death: 1) The
electric wire in question was already installed there two years before the stepbrother’s
house was constructed; 2) Before the house was constructed, the city authorities told the
home owner that he can only build one meter of media agua given that there are live
wires near his window. However, the owner exceeded the permitted size; 3) As to
Efren, the wires were at a considerable distance away from the media agua, that it could
not have been touched if he was not carrying something long enough to reach the wires;
4) Efren was neither a boy nor a person immature in relation to his work. He is a trained
tinsmith, well- experienced in the repair of galvanized iron roofs and media agua; 5)
Efren knew there were wires near the area where he was working but he did not take
caution as he turned around. He should have known better to check first whether the
galvanized iron sheet he was holding would touch the live wires.

Hence, Manila Electric Company’s negligence in the installation and maintenance of its
wires was not the proximate cause of Efren’s death but the latter’s own fault.

DOCTRINE
Remote cause
That which furnishes the condition or gives rise to the occasion by which the injury was
made possible. Such remote cause cannot be the basis of an action if there intervened
between such prior or remote cause and the injury a distinct, successive, unrelated, and
efficient cause of the injury, even though such injury would not have happened but for
such condition or occasion.

Proximate cause
That circumstance which result in injury because of the prior defective condition.

You might also like