G.R. No. 130003 - Anonuevo vs. Court of Appeals

On February 8, 1989, at around 9:00 PM, a collision occurred at the intersection of Boni Avenue and Barangka Drive in Mandaluyong.

Jerome Villagracia was riding his bicycle along Boni Avenue when he was struck by the Lancer car driven by Jonas AAonuevo, who was making a left turn toward Libertad Street.

The impact occurred when AAonuevo’s vehicle hit Villagracia’s left mid-thigh, resulting in a comminuted fracture and other serious injuries.

Villagracia sustained severe injuries that required several hospitalizations during 1989.

These injuries formed the basis of Villagracia’s claim for damages against AAonuevo and the car’s owner.

On October 26, 1989, Villagracia initiated a civil action for damages before the Regional Trial Court (RTC), Branch 160 of Pasig City, against Procter and Gamble Inc. (the owner of the car) and AAonuevo.

The RTC, and later the Court of Appeals, found in favor of Villagracia, ordering AAonuevo (and Procter and Gamble) to pay actual, moral, and attorney’s fees damages.

AAonuevo appealed these decisions, and his petition later raised a singular legal issue regarding the application of Article 2185 by analogy to non-motorized vehicles.

AAonuevo conceded that his vehicular conduct—speeding and failing to decelerate during a left turn—caused the collision.

He contended that Villagracia’s failure to install mandatory safety devices (such as a horn, bell, headlights, and proper brakes) on his bicycle and to register it as required by a 1948 municipal ordinance contributed to the accident.

Based on these alleged regulatory violations, AAonuevo argued that Article 2185 of the New Civil Code, which presumes negligence for drivers of motor vehicles violating traffic regulations, should be applied by analogy to his case involving a bicycle.

Both the RTC and the Court of Appeals confirmed that AAonuevo’s reckless driving (including his speeding and sudden left turn) was the proximate cause of the accident.

The courts noted that the absence of safety gadgets on the bicycle, though acknowledged, was not sufficient to bar recovery because the motorist’s negligence was the direct cause of the collision.

AAonuevo did not dispute the factual findings related to his own negligence but sought relief by shifting the focus to technical omissions on the part of Villagracia.

Whether Article 2185 of the New Civil Code—which presumes the negligence of a motor vehicle driver when violating traffic regulations—can be analogously applied to non-motorized vehicles, such as bicycles.
Whether Villagracia’s failure to equip his bicycle with mandated safety devices and to comply with municipal registration requirements constitutes contributory negligence that should bar or diminish his recovery of damages.
Whether the unsafe acts of Villagracia materially contributed to the accident, considering AAonuevo’s admitted speeding and failure to exercise due caution when executing a left turn.