G.R. No. 171998 - Salazar vs. J.Y. Brothers Marketing Corp.

On February 8, 1989, at around 9:00 PM, at the intersection of Boni Avenue and Barangka Drive in Mandaluyong, petitioner Jonas A. Aonuevo was driving a Mitsubishi Lancer (plate PJJ 359) owned by Procter & Gamble Phils., Inc. and employed by his brother.
At the same time, respondent Jerome Villagracia was traveling on his unregistered bicycle (lacking horn, bell, headlights, and foot brakes) along Boni Avenue. As Aonuevo made a left turn toward Libertad Street, his car struck the cyclist’s left mid-thigh, causing a comminuted fracture, multiple hospitalizations, and four operations in 1989.

On October 26, 1989, Villagracia filed a civil action for damages (Civil Case No. 58784, RTC Pasig City, Branch 160) against Procter & Gamble and Aonuevo. A separate criminal complaint against Aonuevo was later dismissed.
On March 9, 1990, the RTC rendered judgment against both defendants, ordering payment of ₱150,000 actual damages, ₱10,000 moral damages, ₱20,000 attorney’s fees, and costs.
Both defendants appealed to the Court of Appeals. On May 8, 1997, the CA Fourth Division affirmed the RTC decision in toto, and on July 22, 1997 denied reconsideration. Procter & Gamble’s subsequent petition to the Supreme Court was denied on November 24, 1997. Aonuevo’s petition was given due course and is the subject of this decision.

Whether the presumption of negligence under Article 2185 of the New Civil Code—applicable to drivers of motor vehicles violating traffic regulations—should be analogously extended to non-motorized vehicles (i.e., bicycles).

Whether Villagracia’s failure to register his bicycle or install required safety devices and brakes constitutes contributory negligence sufficient to bar or reduce his recovery.