Teague v.

Fernandez

FACTS
 A fire broke out in a store for surplus materials located about ten meters away from the Realistic
Institute lol a beauty school owned and operated by Teague. Students inside the institute panicked.
Four instructresses and six assistant instructress of the Institute were present and they, together with
the registrar, tried to calm down the (180 in total) students.
o However, the panic could not be subdued and the students, with the exception of the few who
made use of fire escapes kept on rushing and pushing their way through the stairs, thereby
causing stampede therein.
o No part of the building caught fire but after the panic was over, four students, including Lourdes
Fernandez, a sister of plaintiffs-appellants, were found dead and several others injured on
account of the stampede. She died from "shock due to traumatic fractures of the ribs with
perinephric hematoma and lacerations of the conjunctiva of both eyes."
 The deceased's five brothers and sisters filed an action for damages against Teague
 CFI: dismissed the case
 CA: reversed, held that Teague was negligent and that such negligence was the proximate cause of the
death of Fernandez.
o This finding of negligence is based primarily on the fact that the provision of Section 491 Of the
Revised Ordinances of the City of Manila had not been complied with in connection with the
construction and use of the Gil-Armi building where the petitioner's vocational school was
housed. Ordered to pay P11,000.00, plus interest.
o The alleged violation of the ordinance consisted in the fact that the second storey of the Gil-Armi
building had only one stairway, 1.5 meters wide, instead of two of at least 1.2 meters each,
although at the time of the fire the owner of the building had a second stairway under
construction.

ISSUE + RULING
Is Teague liable? YES.
 She was negligent and that such negligence was the proximate cause of the death of Lourdes
Fernandez. This finding of negligence is based primarily on the fact that the provision of Section 491 Of
the Revised Ordinances of the City of Manila had not been complied with in connection with the
construction and use of the Gil-Armi building where the petitioner's vocational school was housed.
o "The mere fact of violation of a statute is not sufficient basis for an inference that such violation
was the proximate cause of the injury complained. However, if the very injury has happened
which was intended to be prevented by the statute, it has been held that violation of the statute
will be deemed to be the proximate cause of the injury."
o According to this view it is immaterial, where a statute has been violated, whether the act or
omission constituting such violation would have been regarded as negligence in the absence of
any statute on the subject or whether there was, as a matter of fact, any reason to anticipate
that injury would result from such violation.
 It will be noted from the text of the ordinance, however, that it is not ownership which determines the
character of buildings subject to its requirements, but rather the use or the purpose for which a
particular building is utilized.
o Thus the same may be privately owned, but if it is devoted to any one of the purposes
mentioned in the ordinance for instance as a school, which the Realistic Institute precisely was
then the building is within the coverage of the ordinance. Indeed the requirement that such a
building should have two (2) separate stairways instead of only one (1) has no relevance or
reasonable relation to the fact of ownership, but does have such relation to the use or purpose
for which the building is devoted.
 "The proximate legal cause is that acting first and producing the injury, either immediately or by settling
other events in motion, all constituting a natural and continuous chain of events, each having a close
causal connection with its immediate predecessor, the final event in the chain immediately affecting the
injury as a natural and probable result of the cause which first acted, under such circumstances that the
person responsible for the first event should, as an ordinarily prudent and intelligent person, have
reasonable ground to expect at the moment of his act or default that an injury to some person might
probably result therefrom."
o Having in view the decision just quoted, the petitioner relates the chain of events that resulted in
the death of Lourdes Fernandez as follows: (1) violation of ordinance; (2) fire at a neighboring
place; (3) shouts of "Fire!, Fire!"; (4) panic in the Institute; (5) stampede; and (6) injuries and
death.