iii. Remote Cause

Remote Cause

Concept

A remote cause is an earlier circumstance in a chain of events that helps explain how an injury came about but is not, merely for that reason, the cause to which responsibility is attributed. The inquiry remains whether a party’s negligence was the proximate cause of the injury. (Our Lady of Lourdes Hospital v. Spouses Capanzana, G.R. No. 189218, 22 March 2017)¹ (Abrogar v. Cosmos Bottling Company and Intergames, Inc., G.R. No. 164749, 15 March 2017)²

Governing provisions

Art. 49, Revised Corporation Code concerns meetings of stockholders or members and does not govern the distinction between remote and proximate cause. (Art. 49, Revised Corporation Code)³ Cases on negligence and causation govern the distinction between remote and proximate cause. (Our Lady of Lourdes Hospital v. Spouses Capanzana)¹

Requisites / Rules

• Proximate cause produces the injury in a natural and continuous sequence, unbroken by an efficient intervening cause; without it, the result would not have occurred. (Our Lady of Lourdes Hospital v. Spouses Capanzana)¹
• Recovery of damages requires both a legal wrong by the defendant and resulting damage. An accident or injury alone creates no cause of action. (Spouses Latonio v. Mcgeorge Food Industries Inc., G.R. No. 206184, 6 December 2017)⁴
• In assessing negligence, ask whether a prudent person in the actor’s position could reasonably foresee the harm and therefore should have refrained from the conduct or taken precautions. (Sanggacala v. National Power Corporation, G.R. No. 209538, 7 July 2021)⁵

Distinctions

Do not equate an event’s place earlier in the sequence with its legal significance. The proximate-cause inquiry asks which negligence produced the injury through the required causal sequence. In a fire case, the Court considered the combined effect of proximity, abrasion, and short-circuiting and attributed causation to the party whose act produced that confluence. (Our Lady of Lourdes Hospital v. Spouses Capanzana)¹ (Visayan Electric Company, Inc. v. Alfeche, G.R. No. 209910, 29 November 2017)⁶

Nor does every later negligent act necessarily displace an earlier one. The Court held an organizer’s negligence to be the proximate cause of a death despite the intervening negligence of a jeepney driver. Thus, identify what the later act did to the causal sequence rather than labeling the earlier act remote solely because another act followed it. (Abrogar v. Cosmos Bottling Company and Intergames, Inc.)² (Our Lady of Lourdes Hospital v. Spouses Capanzana)¹

Key doctrines

Where the victim’s own negligence is the proximate cause, third parties are not liable absent independent negligence on their part. Conversely, a defendant’s earlier negligence may remain legally significant even when another person subsequently acts negligently, as the organizer-and-driver ruling illustrates. (Spouses Latonio v. Mcgeorge Food Industries Inc.)⁴ (Abrogar v. Cosmos Bottling Company and Intergames, Inc.)²

Exceptions

No separate exception specific to remote cause is supplied. The stated qualification to the natural-and-continuous-sequence formulation is an efficient intervening cause that breaks that sequence. (Our Lady of Lourdes Hospital v. Spouses Capanzana)¹

Bar tip

Trace the acts in order, then explain why the defendant’s act did or did not remain the proximate cause; do not stop at identifying an earlier condition or a later actor. (Our Lady of Lourdes Hospital v. Spouses Capanzana)¹ (Abrogar v. Cosmos Bottling Company and Intergames, Inc.)²