Davao Del Norte Electric Cooperative v. Heirs of Lucas
REITERATIONFacts
The Antecedents: Respondents, the heirs of Victorino Lucas, filed a complaint for quasi-delict and damages against petitioner Davao Del Norte Electric Cooperative (DANECO). Victorino died after his motorcycle entangled with a low-hanging high-tension electrical wire owned and maintained by DANECO. The incident occurred on November 8, 2001, when Victorino was on his way home. He fell from his motorcycle, hit his head, and died on November 16, 2001, due to severe head injuries. Procedural History: The Regional Trial Court (RTC) ruled in favor of the respondents, holding DANECO liable for various damages, including actual damages, loss of earning capacity, moral damages, exemplary damages, and attorney's fees. The Court of Appeals (CA) affirmed the RTC's decision with modification regarding moral damages and loss of earning capacity. DANECO's motion for reconsideration was denied by the CA. DANECO then filed a Petition for Review on Certiorari with the Supreme Court. The Petition: DANECO assails the CA's affirmation of the RTC's findings of negligence and its ruling that DANECO's negligence was the proximate cause of Victorino's death. DANECO argued that the wire was low-tension, installed according to standards, and that the accident was caused by a fortuitous event (a G.I. sheet blown by strong winds) and Victorino's own recklessness.
Issue(s)
Whether the Court of Appeals committed reversible error in upholding the Regional Trial Court's finding that petitioner was negligent. Whether petitioner's negligence was the proximate cause of Victorino's accident.
Ruling
The Supreme Court denied the petition. It affirmed the Decision of the Court of Appeals, which upheld the Regional Trial Court's finding that DANECO was negligent and that such negligence was the proximate cause of Victorino's death. The Court found no reversible error in the CA's ruling and affirmed the awards for damages.
Ratio Decidendi
On the issue of whether the Court of Appeals committed reversible error in upholding the Regional Trial Court's finding that petitioner was negligent: The Court held that the petition raises questions of fact, which are generally beyond the scope of a Rule 45 petition. The factual findings of the RTC, affirmed by the CA, are conclusive. Furthermore, the Court applied the doctrine of res ipsa loquitur, stating that DANECO, as a public utility, is presumed negligent in the maintenance of its power lines. The evidence presented by respondents, including eyewitness testimonies about the low-hanging and sparking wires, and prior incidents, established a prima facie case of negligence. DANECO failed to adduce sufficient evidence to rebut this presumption, relying only on its own assertions and the alleged hearsay nature of respondents' testimonies. The RTC's observation that DANECO repaired the wires before the ocular inspection further supported the finding of negligence, as it suggested an attempt to conceal the actual condition of the wires at the time of the accident. On the issue of whether petitioner's negligence was the proximate cause of Victorino's accident: The Court found that the causal connection between DANECO's negligence and the damages sustained by respondents was evident. While DANECO argued that a fortuitous event (flying G.I. sheet) and Victorino's own recklessness were the proximate causes, the Court ruled that these were intervening causes that did not break the chain of causation stemming from DANECO's negligence. The accident would not have occurred had DANECO exercised due diligence in maintaining its power lines and ensuring safety measures. Therefore, DANECO could not escape liability by attributing the accident to Victorino or to a fortuitous event. The Court affirmed the CA's award of damages, finding them justified under the circumstances, including actual damages, loss of earning capacity, moral damages, exemplary damages, and attorney's fees, all bearing legal interest.
Main Doctrine
A public utility like an electric cooperative is presumed negligent in the maintenance of its power lines under the doctrine of res ipsa loquitur, and must present sufficient evidence to rebut this presumption. Failure to do so, coupled with evidence of an accident caused by a low-hanging wire, establishes proximate cause for damages.