In Davao Del Norte Electric Cooperative v. Heirs of Victorino Lucas, the Supreme Court affirmed the liability of Davao Del Norte Electric Cooperative (DANECO) for damages resulting from the death of Victorino Lucas, who was fatally injured after his motorcycle became entangled with a low-hanging electrical wire maintained by DANECO. The Court applied the doctrine of res ipsa loquitur, establishing a presumption of negligence on DANECO’s part due to its failure to properly maintain its power lines, which ultimately led to the tragic accident. This decision underscores the responsibility of utility companies to ensure the safety of their infrastructure and the public, reinforcing the principle that negligence leading to harm must be adequately compensated.

Fallen Wires, Fatal Ride: Who Bears the Responsibility?

The case revolves around an incident on November 8, 2001, when Victorino Lucas, while riding his motorcycle, encountered a low-hanging electrical wire owned and maintained by DANECO. The wire caused him to fall, resulting in severe head injuries that led to his death eight days later. The heirs of Victorino Lucas filed a complaint for quasi-delict, alleging DANECO’s negligence in maintaining its power lines. DANECO countered that the wire was low-tension and maintained according to industry standards, attributing the incident to a fortuitous event—strong winds causing a G.I. sheet to sever the wire—and Victorino’s alleged reckless driving.

The trial court found DANECO negligent, a decision affirmed with modifications by the Court of Appeals (CA). The CA relied on the doctrine of res ipsa loquitur, which presumes negligence when an accident occurs that ordinarily would not in the absence of negligence. The Supreme Court upheld the CA’s ruling, emphasizing that DANECO failed to rebut the presumption of negligence established by the circumstances of the accident. This failure solidified DANECO’s liability for the damages suffered by the heirs of Victorino Lucas, holding the electric cooperative accountable for its inadequate maintenance of power lines.

The Supreme Court underscored the elements necessary to establish a claim based on quasi-delict under Article 2176 of the New Civil Code, which states:

Art. 2176. Whoever by act or omission causes damage to another, there being fault or negligence, is obliged to pay for the damage done. Such fault or negligence, if there is no pre-existing contractual relation between the parties, is called a quasi-delict x x x.

These elements include: (a) damage suffered by the plaintiff; (b) fault or negligence of the defendant; and (c) a causal connection between the defendant’s negligence and the damage incurred, known as proximate cause. The Court found that all these elements were sufficiently proven by the respondents. It was undisputed that the respondents suffered damage due to Victorino’s death, and DANECO even provided financial assistance. However, this assistance was not an admission of liability but rather a humanitarian gesture. The crux of the matter was establishing DANECO’s negligence and its direct link to Victorino’s death.

The Court then addressed the critical aspect of negligence, highlighting that under the doctrine of res ipsa loquitur, negligence is presumed when the incident speaks for itself. This doctrine, as applied in Allarey v. Dela Cruz, allows for an inference of negligence when the accident is of a kind that ordinarily does not occur without negligence, is caused by an instrumentality within the exclusive control of the defendant, and the possibility of contributory conduct by the plaintiff is eliminated. The Court stated:

x x x [I]t is considered as merely evidentiary or in the nature of a procedural rule. It is regarded as a mode of proof, of a mere procedural convenience since it furnishes a substitute for, and relieves a plaintiff of, the burden of producing specific proof of negligence. In other words, mere invocation and application of the doctrine does not dispense with the requirement of proof of negligence. It is simply a step in the process of such proof, permitting the plaintiff to present along with the proof of the accident, enough of the attending circumstances to invoke the doctrine, creating an inference or presumption of negligence, and to thereby place on the defendant the burden of going forward with the proof.

In this case, the Court found that the low-hanging electrical wires, exclusively managed and controlled by DANECO, created an unusual and dangerous situation. The accident would not have occurred without some form of negligence on DANECO’s part. This shifted the burden to DANECO to prove it was not negligent, a burden it failed to meet. Even though DANECO argued that strong winds and a flying G.I. sheet were intervening causes, the Court determined that these did not break the causal connection between DANECO’s negligence and Victorino’s injuries. The accident could have been prevented if DANECO had properly maintained its power lines.

Finally, the Court addressed the issue of damages. The Court recognized the appropriateness of actual or compensatory damages, indemnity for loss of earning capacity, moral damages, and exemplary damages, as awarded by the lower courts. The Court of Appeals found that Victorino’s income-earning capacity had been sufficiently established by his Income Tax Return that reflected his annual gross taxable income at P102,746.04. Applying the formula outlined by recent jurisprudence in computing the compensable amount for loss of earning capacity, the Court affirmed that the CA’s award to respondents for Victorino’s loss of earning capacity in the amount of P684,802.357 was in order. As for exemplary damages, the Court highlighted the importance of correcting and disciplining DANECO. Such was the act of hiring and paying lawyers to deny its responsibility and even paying its lone witness P100,000.00 to support its claim of non-liability, instead of taking responsibility for its negligence by supporting the respondents’ medical needs and by settling the matter amicably and expeditiously with the respondents.

FAQs

What was the key issue in this case?	The key issue was whether Davao Del Norte Electric Cooperative (DANECO) was liable for damages resulting from the death of Victorino Lucas due to a low-hanging electrical wire. The Court examined whether DANECO’s negligence was the proximate cause of the accident.
What is the doctrine of res ipsa loquitur?	The doctrine of res ipsa loquitur presumes negligence when an accident occurs that ordinarily would not happen in the absence of negligence. It shifts the burden of proof to the defendant to show they were not negligent.
What is quasi-delict?	Quasi-delict is an act or omission that causes damage to another due to fault or negligence, without a pre-existing contractual relationship. Article 2176 of the New Civil Code governs quasi-delicts.
What elements are needed to prove quasi-delict?	To establish a claim based on quasi-delict, there must be damage suffered by the plaintiff, fault or negligence of the defendant, and a causal connection between the defendant’s negligence and the damage incurred. This connection is referred to as the proximate cause.
What was the court’s ruling on DANECO’s negligence?	The court ruled that DANECO was negligent in the maintenance of its power lines, applying the doctrine of res ipsa loquitur. DANECO failed to rebut the presumption of negligence, making it liable for the damages.
How did the court determine proximate cause in this case?	The court determined that DANECO’s negligence in maintaining the power lines was the proximate cause of the accident. The low-hanging wire, directly resulting from DANECO’s failure to maintain it, led to Victorino’s injuries and subsequent death.
What types of damages were awarded in this case?	The damages awarded included actual or compensatory damages, indemnity for loss of earning capacity, moral damages, exemplary damages, attorney’s fees, and costs of suit. These damages aimed to compensate the heirs for the losses and suffering caused by Victorino’s death.
Why was DANECO ordered to pay exemplary damages?	DANECO was ordered to pay exemplary damages due to its gross negligence and bad faith. The court cited DANECO’s hiring of lawyers to deny responsibility, paying a witness, and repairing the wires before the ocular inspection without informing the court.

The Supreme Court’s decision in Davao Del Norte Electric Cooperative v. Heirs of Victorino Lucas serves as a stern reminder to utility companies about their duty to ensure public safety through proper maintenance of their facilities. By upholding the principles of quasi-delict and applying the doctrine of res ipsa loquitur, the Court has reinforced the importance of accountability and diligence in preventing harm. This case underscores the responsibility of utility providers to prioritize safety and proactively address potential hazards to protect the lives and well-being of the communities they serve.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Davao Del Norte Electric Cooperative v. Heirs of Victorino Lucas, G.R. No. 254395, June 14, 2023