This case involves a claim for damages that arose from negligence and caused the death of Angelo (not his real name), a participant in an organized running event, who was bumped by a jeepney during the race.
To promote sales of their products, Sponsorships Company (not its real name), together with Running Events Inc. (not its real name), organized a running event for 14-18-year-olds scheduled to be held in June 1980.
The organizers set the 10-km course, which notably passed through public roads. Angelo joined the event and ran the course that the organizers plotted which, according to Angelo’s parents, lacked adequate safety and precautionary measures that were required. Angelo was bumped by a jeepney that was running along the route of the race, and despite the medical treatment that he received in a nearby hospital, he passed away on the same day by reason of severe head injuries.
Angelo’s parents filed a case to recover damages due to Angelo’s untimely death. Sponsorships Company denied its liability, claiming that it was not the organizer and was merely a sponsor of the race. Running Events Inc. insisted that Angelo’s death was an accident exclusively caused by the jeepney driver’s negligence.
The Regional Trial Court found in favor of Angelo’s parents. The Court of Appeals, on the other hand, held that Running Events Inc. was not negligent in organizing the race, and that the doctrine of assumption of risk was applicable.
Was Running Events Inc. negligent as the organizer and resultantly the proximate cause of Angelo’s death?
Yes. The Supreme Court took note that Running Events Inc. had no employees of its own and only relied on cooperating agencies and volunteers that had assisted them in their previous races. Despite the claimed ocular inspection, letters to agencies, permits from authorities, directional signs and water stations, the Supreme Court considered these supposed safeguards to be inadequate for consideration as due diligence.
Running Events Inc. knew they were prohibited by police authorities from blocking one of the highways, and they had a choice to hold the race in a different location. Their familiarity with the route and the lack of untoward incidents from past events were also not considered to be sufficient safeguards. The Supreme Court considered the number of personnel to be sufficient to stage a marathon, but not to ensure its safe administration.
Further, the participants’ youth, eagerness and inexperience, considering the race was a junior marathon where the participants were composed of young persons aged 14-18, were held to be factors that should have placed an organizer on higher guard in relation to their safety and security needs, and that a higher degree of diligence was required.
The negligence of Running Events Inc., despite the jeepney driver’s negligence, was considered to be the proximate cause of the death. The negligence of Running Events Inc. set the stage for the resulting injury. It could have been avoided if they acted with due diligence and had the race on a safer road with more efficient supervision.
The jeepney driver’s negligence may be considered intervening, but it was not considered an efficient intervening cause because it did not break the chain of connection between Running Events Inc.’s negligence and the resulting death. Running Events Inc. had the duty to guard Angelo against this foreseeable risk, but it was unable to do so.
Is the doctrine of assumption of risk applicable in Angelo’s case?
No. Angelo could not have assumed the risk because death was not a known or a normal risk of running a race. Even though he surveyed the route and presumably knew he would run alongside moving vehicles, the knowledge of the general danger cannot be considered to be enough. Angelo could not have appreciated the risk of being disastrously bumped by a jeepney while running the race. He had every reason to trust that the organizers took the necessary measures to protect participants from danger.
The Supreme Court went as far to say that nobody in their right mind, including minors, would join the race if they knew or appreciated the risk of harm or death from a vehicle while running in the event. A race route that is safe and free from such risks is a reasonable expectation of any runner in any organized run.
Should Sponsorships Company also be held liable?
No. Sponsorships Company, as the sponsor, was limited to financing the run. Absent any showing that they played a part in organizing the race and deciding on the route, including the safety measures, the Court cannot consider there to be a direct causal connection to Angelo’s death.
Sponsorships Company is absolved from liability; Running Events, Inc. was ordered to pay damages to the petitioners’ parents of Angelo. (Abrogar v. Cosmos Bottling Company and Intergames, Inc., G.R. No. 164749, 15 March 2017.)
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