### Facts:
**Series of Events:**
1. **September 13, 1952:** Bus No. 30 of Medina Transportation, driven by Conrado Saylon, departed from Amadeo, Cavite, towards Pasay City at around midnight.
2. **Passengers:** Approximately eighteen passengers, including Juan Bataclan, were aboard.
3. **Accident:** At around 2:00 AM, while the bus was within Imus, Cavite, a front tire burst, causing the vehicle to zigzag and ultimately fall into a roadside ditch, overturning and trapping four passengers.
4. **Rescue Attempts:** Passengers attempted to extricate themselves while others called for help. After about 30 minutes, locals arrived with a lighted torch, unintentionally igniting leaked gasoline and setting the bus on fire, leading to the deaths of the trapped passengers.
**Procedural Posture:**
1. **Trial Court:** Salud Villanueva sued Mariano Medina for damages. The Court of First Instance of Cavite awarded P1,000 in damages, P600 in attorney’s fees, and P100 for lost merchandise.
2. **Appeal:** Both parties appealed to the Court of Appeals, arguing over liability and the degree of damages awarded.
3. **Supreme Court:** The case was forwarded to the Supreme Court due to the amount involved in the claim.
### Issues:
1. **Degree of Negligence:** Whether Mariano Medina, through his agents, exhibited negligence leading to the accident and subsequent death of the passengers.
2. **Proximate Cause:** Whether the proximate cause of the deaths was the overturning of the bus or the fire that ensued.
3. **Damages:** The appropriate amount of compensatory, moral, and exemplary damages to be awarded to the plaintiffs.
### Court’s Decision:
**Negligence:**
– The Supreme Court held that there was evident negligence on the part of the defendant. The bus was speeding, making it difficult to control after the tire burst.
– Medina’s bus driver failed to exercise the diligence required of common carriers under the New Civil Code, particularly Articles 1733, 1755, 1756, 1759, and 1763.
**Proximate Cause:**
– The Court determined that the proximate cause of the deaths was the overturning of the bus, as it set off a chain of events leading to the fire. The presence of leaking gasoline and the rescuers’ lighted torch, in the darkness and rural setting, were foreseeable events following the overturning.
**Damages Awarded:**
– The Supreme Court modified the trial court’s decision by increasing the total compensatory damages to P6,000, reflecting the full extent of the loss, including moral damages.
– Attorney’s fees were also increased to P800, taking into account the extensive litigation required.
– The loss of merchandise remained valued at P100.
### Doctrine:
– **Common Carrier’s Duty of Extraordinary Diligence:** Common carriers have an absolute duty to observe extraordinary diligence in ensuring passenger safety.
– **Proximate Cause:** The proximate cause is defined as the primary cause that sets in motion a sequence of events, leading to the injury or damage, which is a foreseeable result of the first event.
### Class Notes:
– **Key Elements:**
– **Common Carrier Responsibility:** Articles 1733, 1755, 1756, 1759, and 1763 of the New Civil Code emphasize a common carrier’s extraordinary diligence in passenger safety.
– **Negligence:** Negligence is determined by the carrier’s failure to fulfill its duty to protect passengers, and proximate cause extends to all foreseeable consequences.
– **Proximate Cause:** Defined comprehensively as the initial cause that sets off a natural sequence of events leading to the injury without any efficient intervening causes.
### Historical Background:
– **Transportation Safety:** The case highlights transportation safety concerns in the early 1950s rural Philippines, emphasizing the critical need for diligence among public transport operators.
– **Legal Precedents:** The decision reinforced the stringent standards applied to common carriers, aligning with public policy interests in passenger safety, and demonstrated the judiciary’s role in enforcing these standards to prevent future negligence.
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