ii. Intervening Cause

Intervening Cause

Concept

An intervening cause is an event or act that occurs within the sequence between an earlier act and an injury. Its significance is whether it breaks the causal connection: proximate cause produces injury in a natural and continuous sequence, unbroken by an efficient intervening cause, and without it the injury would not have occurred. The occurrence of a later act does not, by itself, settle that question. (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

Article 2176 of the Civil Code requires a person whose act or omission causes damage to another through fault or negligence to pay for that damage. It calls such fault or negligence a quasi-delict when the parties have no pre-existing contractual relation. In applying the provision, the inquiry includes whether the defendant’s negligence caused the injury, not merely whether negligence and injury occurred. (Art. 2176, Civil Code)³ (Kim v. Slimmers World International, G.R. No. 206306, 3 April 2024)⁴

Requisites / Rules

• Identify the alleged negligent act, the resulting injury, and any later act said to intervene. A damages claim based on quasi-delict must be supported by preponderant evidence of negligence and a causal connection to the injury. (Kim v. Slimmers World International)⁴
• Ask whether the earlier negligence remained connected to the injury in a natural and continuous sequence, or whether an efficient intervening cause broke that sequence. This is the proximate-cause inquiry, not a rule that every later event ends liability. (Our Lady of Lourdes Hospital v. Spouses Capanzana)¹
• Examine the actual sequence of events. A confluence of factors may lead to injury, with causation attributed to the party whose act produced that confluence. (Visayan Electric Company, Inc. v. Alfeche, G.R. No. 209910, 29 November 2017)⁵

Distinctions

An intervening act is a later occurrence in the chain; an efficient intervening cause is one that breaks the sequence required for the earlier act to be the proximate cause. Conversely, a later person’s negligence can intervene without displacing the causal significance of the earlier negligence. The distinction turns on causation in the proved circumstances, not simply on which act occurred last. (Our Lady of Lourdes Hospital v. Spouses Capanzana)¹ (Abrogar v. Cosmos Bottling Company and Intergames, Inc.)²

Key doctrines

In Abrogar, the Court held that Intergames’ negligence was the proximate cause of death despite the intervening negligence of a jeepney driver. The Court assessed responsibility in the chain of events by considering whether the result was a natural and probable consequence of the negligence. Thus, the driver’s intervening negligence did not, on those facts, relieve Intergames of liability. (Abrogar v. Cosmos Bottling Company and Intergames, Inc.)²

By contrast, where the victim’s own negligence is the proximate cause and the defendants have no independent negligence, those defendants cannot be held liable. An injury alone, without a legal wrong by the defendant that results in damage, does not establish a cause of action. (Spouses Latonio v. Mcgeorge Food Industries Inc., G.R. No. 206184, 6 December 2017)⁶

Exceptions

There is no automatic exception under which every intervening act excuses an earlier negligent actor. Abrogar illustrates that liability may remain despite another person’s intervening negligence; the controlling issue remains whether the earlier act was the proximate cause of the injury. (Abrogar v. Cosmos Bottling Company and Intergames, Inc.)² (Our Lady of Lourdes Hospital v. Spouses Capanzana)¹

Bar tip

Trace the acts in order, then explain whether the later act broke the natural and continuous causal sequence. Do not treat “intervening” as synonymous with “efficient intervening.” (Our Lady of Lourdes Hospital v. Spouses Capanzana)¹ (Abrogar v. Cosmos Bottling Company and Intergames, Inc.)²