Civil Law and Land Titles and Deeds › Torts and Quasi-delicts › Proximate Cause › Concept › Distinguished from

iv. Concurrent Cause

Principle of concurrent causes

Where the concurrent or successive negligent acts or omissions of two or more persons, although acting independently, are in combination the direct and proximate cause of a single injury to a third person, and it is impossible to determine what proportion each contributed to the injury, either of them is responsible for the whole injury, even though his act alone might not have caused the entire injury. (Sabido v. Custodio, G.R. No. L-21512, August 31, 1966)

Efficient Intervening Cause (Novus Actus Interveniens)

An efficient intervening cause is one which destroys the causal connection between the negligent act and the injury and thereby negates liability. (Morril v. Morril, 60 ALR 102, 104 NJL 557)

Concurrent Negligence of Two or More Persons

Where the concurrent or successive negligent acts or omissions of two or more persons, although acting independently, are in combination the direct and proximate cause of a single injury to a third person, and each person’s proportionate contribution cannot be determined, each may be held responsible for the whole injury. (Sabido v. Custodio, G.R. No. L-21512, August 31, 1966)

Authorities

  • Morril v. Morril
  • Sabido v. Custodio, G.R. No. L-21512, 31 August 1966