CIVIL LAW > XI. QUASI-DELICTS > C. Proximate Cause > 1. Concept > b. Distinguished from Intervening Cause
Overview
The distinction between proximate cause and intervening cause is crucial in determining liability in quasi-delicts. Both concepts are essential in analyzing causation, but they have distinct implications in law. Below is a meticulous exposition of their definitions, applications, and differences under Philippine law.
Proximate Cause: Definition and Elements
Proximate cause refers to the primary or direct cause that sets in motion an unbroken chain of events leading to the injury or damage complained of. It is the cause that is legally sufficient to result in liability. Under Article 2176 of the Civil Code, proximate cause plays a pivotal role in establishing the causal connection between the defendant's act or omission and the resulting harm.
Key Elements of Proximate Cause:
- Direct Causation: It must directly bring about the injury without the intervention of an independent and adequate cause.
- Unbroken Chain of Events: There must be continuity between the wrongful act and the damage, without substantial interruption.
- Foreseeability: The injury must be a natural and probable consequence of the act or omission, foreseeable by a person of ordinary prudence.
Intervening Cause: Definition and Characteristics
An intervening cause is an event or act that occurs after the defendant's wrongful act but before the injury, which contributes to or exacerbates the harm. It can either:
- Break the causal chain (thus relieving the defendant of liability), or
- Merge with the original act to establish concurrent causation, maintaining or even amplifying the defendant's liability.
Characteristics of Intervening Cause:
- Superseding Nature: It must independently and adequately cause the injury, severing the link between the defendant’s act and the damage.
- Unforeseeability: It is generally an unexpected event that could not have been reasonably anticipated by the original wrongdoer.
- Independent Action: It arises independently of the defendant’s initial act.
Key Distinctions: Proximate Cause vs. Intervening Cause
| Aspect | Proximate Cause | Intervening Cause |
|---|---|---|
| Definition | Primary cause directly leading to harm. | A subsequent, independent event affecting harm. |
| Role in Causation | Establishes liability by linking act to harm. | May break or modify the causal connection. |
| Foreseeability | Always foreseeable as a natural consequence. | Generally unforeseeable and unexpected. |
| Effect on Liability | Imposes liability on the original wrongdoer. | May absolve or reduce liability. |
| Connection to Act | Unbroken and direct chain of events. | Arises independently and may disrupt causation. |
Examples
Proximate Cause:
- A driver speeds through a red light and hits a pedestrian. The act of speeding and ignoring traffic rules is the proximate cause of the pedestrian’s injury.
Intervening Cause:
- A driver negligently leaves a vehicle parked on a hill without engaging the handbrake. Hours later, an earthquake dislodges the vehicle, causing it to roll downhill and injure a bystander. The earthquake may be considered an intervening cause.
Legal Principles Governing Intervening Causes
1. Superseding Cause Doctrine
If an intervening cause is so substantial and unforeseeable that it overrides the defendant’s original act, it is termed a superseding cause. In such cases, the original act ceases to be the proximate cause, and liability may not attach to the defendant.
2. Concurrent Causes
If the intervening cause is foreseeable or insufficiently breaks the chain of causation, the defendant remains liable. For instance, if an injured person fails to seek prompt medical treatment, the worsening of their injury due to medical neglect may not absolve the original wrongdoer of liability.
Relevant Case Law in the Philippines
Philippine Rabbit Bus Lines v. Ibarra, G.R. No. L-21291 (1968):
- The Supreme Court emphasized the role of proximate cause as the dominant reason for an injury, distinguishing it from incidental or contributory factors.
Valenzuela v. Court of Appeals, G.R. No. 110954 (1995):
- Clarified that an intervening act will not absolve a defendant if it was reasonably foreseeable.
Pineda v. Court of Appeals, G.R. No. 116691 (1996):
- The Court ruled that an intervening event must be sufficiently independent and unforeseeable to sever the causal chain.
Foreseeability Test and Practical Implications
In determining whether an intervening cause absolves liability:
- Foreseeability Test: Was the intervening cause reasonably predictable at the time of the original negligent act?
- Substantial Factor Test: Did the original act remain a substantial factor in causing the harm?
Conclusion
The distinction between proximate and intervening causes lies in their roles and effects on causation. While proximate cause establishes the direct liability of the wrongdoer, an intervening cause can either sustain or disrupt that liability depending on its nature. Philippine jurisprudence underscores the importance of foreseeability and the continuity of the causal chain in deciding such matters. A meticulous understanding of these principles ensures accurate application in quasi-delict cases.