GR 29745; (June, 1973) (Digest)
G.R. No. L-29745. June 4, 1973.
MERCEDES M. TEAGUE, petitioner, vs. ELENA FERNANDEZ, et al., respondents.
FACTS
Petitioner Mercedes M. Teague owned and operated the Realistic Institute, a vocational school located on the second floor of the Gil-Armi Building in Manila. On October 24, 1955, a fire broke out in a store across the street. Although the fire did not reach the school, panic ensued among the approximately 180 students present. Despite efforts by the staff to calm them and direct an orderly evacuation, a stampede occurred on the single stairway. Lourdes Fernandez, a student, died from injuries sustained in the stampede.
The deceased’s siblings filed a damages suit against Teague. The Court of First Instance dismissed the complaint. The Court of Appeals reversed, finding Teague negligent for violating Manila City Ordinance Section 491, which required buildings like schools to have at least two unobstructed stairways. The Gil-Armi Building had only one stairway at the time, though a second was under construction. The appellate court held this violation constituted negligence per se and was the proximate cause of the death.
ISSUE
Was the violation of the city ordinance requiring two stairways the proximate cause of Lourdes Fernandez’s death, thereby establishing Teague’s liability for damages?
RULING
Yes. The Supreme Court affirmed the Court of Appeals’ decision. The legal logic centers on the doctrine of negligence per se and proximate causation. Violation of a statute or ordinance prescribed for public safety constitutes negligence per se. Here, Section 491 of the Revised Ordinances of Manila mandated two stairways for schools precisely to prevent the danger of overcrowding during emergency evacuations.
The Court rejected the petitioner’s argument that the panic and stampede were independent intervening causes breaking the chain of causation. The ordinance was designed to prevent the exact type of injury that occurred—death or injury from a stampede during a panicked evacuation caused by insufficient exits. The violation was a continuing condition that existed when the emergency arose. The overcrowding at the single stairway was the immediate proximate cause of death, and this was the precise contingency the ordinance aimed to prevent. Therefore, the statutory violation was the proximate cause of the injury. The complaint sufficiently alleged negligence by citing the failure to provide adequate fire exits. Teague’s liability for damages was thus upheld.