Topic: Causation

Case Title : Bataclan v. Medina L- 10126

Facts:
On September 13 1952, the defendant Mariano Medina was driving his chauffeur from
Amadeo Cavite to Pasay. There were about 18 passenger including him and his wife. Among
the passenger was the Amadeo Bataclan. At about 2 am in the morning, the front tire of his
vehicle burst and fell in the canal. Then, they asked for help and fortunately 10 men heard and
approached them. One of them was carrying a lighted torch that resulted for a fierce fire to
start. It appeared that the gasoline of the vehicle leaked. Thus, as a result its four passenger
were burned alive.

The case was brought to the Trial Court to determine the proximate cause of Mr.
Bataclan.

The trial court was on the opinion that the proximate cause of death of Bataclan was
not the overturning of the bus but rather the fire that burned the bus.

Issue: Whether the determination of proximate cause of the death of Bataclan valid?

Ruling: No. The Supreme Court held that the proximate cause was the overturning of the bus.
This resulted in the leak of the gasoline which is not natural in the common scenario. Further,
it also resulted to the coming of men to rescue them that were later on became the start of the
flame. In other words, the coming of men with torch was to be expected and the natural
sequence of the overturning of the bus. The burning of the bus can also be attributed to the
negligence of the carrier.