National Power Corp. v. Heirs of Casionan
REITERATIONFacts
The Antecedents: Respondents are the heirs of Noble Casionan, who died at 19 years old due to electrocution on June 27, 1995. Petitioner, National Power Corporation (NPC), had installed high-tension electrical transmission lines (69 KV) traversing a trail in Dalicno, Itogon, Benguet, which was regularly used by the community. Over time, some lines sagged to about eight to ten feet from the ground, posing a danger. Despite verbal and written requests from community elders as early as 1991 for NPC to install safety measures, the lines remained unrepaired. On June 27, 1995, Noble and a co-worker were carrying bamboo poles for pocket mining. While walking under the NPC lines, the tip of the bamboo pole Noble was carrying touched a dangling high-tension wire, causing him to be electrocuted and die instantly. A post-mortem examination confirmed electrocution as the cause of death. Police investigators noted the low-hanging wires, the trail's necessity, and the absence of warning signs. NPC later repaired the lines and installed warning signs after the incident. Procedural History: The heirs of Noble Casionan filed a claim for damages against NPC. The Regional Trial Court (RTC) found NPC guilty of negligence (quasi-delict) and ordered it to pay various damages, including indemnity for death, moral damages, exemplary damages, actual damages, loss of unearned income, and attorney's fees. The RTC gave credence to the eyewitness testimony of Noble's co-worker and found NPC's negligence established by preponderance of evidence, citing prior requests for repairs that were ignored. NPC appealed to the Court of Appeals (CA), arguing it was not liable, and even if electrocution occurred, Noble was contributorily negligent, and the damages were excessive. The CA affirmed the RTC's decision but modified it by reducing moral damages and deleting attorney's fees. The Petition: NPC filed a petition for review on certiorari with the Supreme Court, seeking mitigation of damages on the ground of contributory negligence and deletion of awards for unearned income, exemplary, and moral damages for lack of factual and legal bases.
Issue(s)
Whether the award for damages should be deleted in view of the contributory negligence of the victim. Whether the award for unearned income, exemplary, and moral damages should be deleted for lack of factual and legal bases.
Ruling
The petition is DENIED and the appealed decision of the Court of Appeals is AFFIRMED.
Ratio Decidendi
On the issue of contributory negligence: The Supreme Court affirmed the findings of the lower courts that the victim, Noble Casionan, was not guilty of contributory negligence. The Court emphasized that the sagging high-tension wires, hanging only 8 to 10 feet from the ground in violation of the required 18 to 20 feet clearance, constituted an "accident waiting to happen." Petitioner NPC could not excuse its failure to maintain the wires by attributing negligence to the victim. The Court cited Ma-ao Sugar Central Co., Inc. v. Court of Appeals, holding that the responsibility for maintaining safety lies with the company, and it should not wait for a life to be lost due to its negligence. Furthermore, there were no warning signs installed on the trail, which was the only viable route for the community members, including Noble. The fact that pocket mining was prohibited in the area did not absolve NPC of its duty to ensure the safety of its transmission lines, as the miners, despite lacking permits, were still human beings trying to earn a living. The Court reiterated that for contributory negligence to exist, the victim's act must have been a contributing cause to the harm suffered, falling below the standard of care for his own protection, and there was no showing that Noble acted with disregard for known dangers. On the award for unearned income, exemplary, and moral damages: The Court sustained the trial court's computation of unearned income, applying the formula [2/3 x (80 – age at time of death) x (gross annual income – reasonable and necessary living expenses)]. Noble, being 20 years old at the time of death, had an expected life span of 60 more years. His gross annual income was P36,000.00. The Court applied the 50% deduction for necessary living expenses, as established in People v. Quilaton, resulting in an award of P720,000.00 for loss of unearned income, representing the support his heirs would have received. The Court affirmed the award of exemplary damages, finding that NPC was guilty of gross negligence. This was evidenced by its failure to address the sagging high-tension wires despite numerous previous requests and warnings from the community. NPC only took action after a death occurred, demonstrating a "thoughtless disregard of consequences without exerting any effort to avoid them." The Court sustained the CA's reduction of moral damages from P100,000.00 to P50,000.00. It reiterated that moral damages are compensatory, not punitive, and should not enrich the complainant but help alleviate their suffering. The CA's reduction was deemed appropriate to avoid exorbitant awards. The Court affirmed the CA's deletion of attorney's fees. It cited the well-settled rule that the reason for the award of attorney's fees must be discussed in the body of the decision, not just in the dispositive portion. Since the RTC failed to provide such a discussion, the CA correctly disallowed the award.
Main Doctrine
The National Power Corporation (NPC) is liable for damages for the death of Noble Casionan due to electrocution from its high-tension transmission lines, as the sagging wires constituted an accident waiting to happen, and the victim was not guilty of contributory negligence.