Teague v. Fernandez
REITERATIONFacts
The Antecedents: The Realistic Institute, a vocational school for hair and beauty culture owned by petitioner Mercedes M. Teague, was located on the second floor of the Gil-Armi Building. On October 24, 1955, a fire broke out in a nearby store. Students in the institute panicked, leading to a stampede on the building's single stairway. Despite no part of the building catching fire, four students, including Lourdes Fernandez, died due to the stampede, and several others were injured. Procedural History: The deceased's siblings filed an action for damages against Teague. The Court of First Instance dismissed the case. The Court of Appeals, by a divided vote, reversed the decision and ordered Teague to pay damages. The Petition: The case reached the Supreme Court on a petition for review filed by Teague, challenging the Court of Appeals' finding of negligence and proximate cause.
Issue(s)
Whether Section 491 of the Revised Ordinances of the City of Manila, requiring at least two unobstructed stairways for certain buildings, applied to the Gil-Armi building. Whether the obligation to comply with the ordinance devolved upon the building owner or the lessee (petitioner). Whether the petitioner's failure to comply with the ordinance was the proximate cause of the death of Lourdes Fernandez.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, holding petitioner Mercedes M. Teague liable for damages.
Ratio Decidendi
On the applicability of Section 491 of the Revised Ordinances of the City of Manila: The Court held that the ordinance applied to the Gil-Armi building because its use as a school brought it within the purview of the ordinance, regardless of ownership. The ordinance's requirements were based on the building's utilization, not its proprietary status. The fact that the building was a 'school' as defined in the ordinance was sufficient to bring it under its coverage, even if privately owned. On the obligation to comply with the ordinance: The Court ruled that while the building owner might have had a responsibility, the petitioner, as the lessee responsible for the school's operation, was liable for the violation. The ordinance's coverage was triggered by the use of the building for school purposes, a use for which the petitioner was responsible. Therefore, the petitioner could not evade liability by claiming the obligation belonged solely to the building owner. On whether the failure to comply with the ordinance was the proximate cause of the death: The Court found that the petitioner's non-compliance with the ordinance was the proximate cause of the death. The ordinance requiring two stairways was a safety measure intended to prevent undue overcrowding during emergencies. The fire in the neighborhood, leading to panic and a stampede, created the very situation the ordinance aimed to prevent. The Court cited authorities stating that if the very injury intended to be prevented by a statute or ordinance occurs, its violation is deemed the proximate cause. The intervening events of fire, panic, and stampede did not break the chain of causation, as they were foreseeable contingencies that the ordinance sought to mitigate by ensuring adequate egress.
Main Doctrine
The violation of a safety ordinance, particularly one intended to prevent a specific hazard, constitutes negligence per se, and such violation can be considered the proximate cause of an injury if the accident that occurred was precisely the event the ordinance was designed to prevent, even if intervening events contributed to the harm.