Facts:

On January 12, 1958, a serious incident occurred in Taal, Batangas, when a passenger jeepney owned by spouses Pedro Gahol and Luisa Alcantara, and driven by their regular driver Pepito Buno, was parked on the road. This jeepney was overloaded with passengers, carrying 14 passengers, exceeding its maximum capacity of 11 passengers, including the driver. While parked, Buno had left part of the jeepney on the asphalted part of the road after stopping to let a passenger alight. Approximately five minutes later, a speeding water truck, owned by spouses Anselmo Maligaya and Ceferina Aro and driven by Guillermo Razon, collided violently into the back of the parked jeepney. The collision was so severe that it resulted in the deaths of three passengers and significant injuries to two others, necessitating hospitalization. Subsequently, in February 1958, the representatives of the deceased and injured passengers filed lawsuits to claim damages against both drivers and the owners of the in

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Facts:

Incident and Circumstances

• On January 12, 1958, at around noon, a passenger jeepney was parked on the road to Taal, Batangas.
• The jeepney, allegedly operated by defendant Pepito Buno and owned by Pedro Gahol and Luisa Alcantara, was on its regular route from Mahabang Ludlod to the poblacion of Taal.
• The vehicle was overloaded at the time – it had a capacity of eleven passengers (including the driver) but was carrying more (testimonies cited fourteen to sixteen passengers).
• While parked with one-half of its width on the asphalted road and the other half on the road shoulder (stopped to allow a passenger to alight), the jeepney was struck from behind.
• A speeding water truck, bearing plate No. T-17526 and owned by defendants Anselmo Maligaya and Ceferina Aro, driven by Guillermo Itazon, collided violently with the parked jeepney, causing it to turn turtle into a nearby ditch.
• The resulting collision led to three passenger deaths and multiple injuries, with two passengers sustaining injuries severe enough to require prolonged hospitalization.

Procedural History and Lower Court Rulings

• In February 1958, suits were instituted by representatives of both the deceased passengers and those injured to recover consequential damages against both the truck and jeepney operators.
• The Batangas trial court rendered a judgment that absolved the jeepney driver and its owners while holding the truck driver and owners liable for the damages.
• The plaintiffs appealed this decision, insisting that the negligence of the jeepney operator should also render him and his owners liable for the injuries sustained by the passengers.
• The Court of Appeals sustained the exoneration of the jeepney driver and its owners by noting that although the jeepney driver was negligent in the manner of parking his vehicle, the truck driver’s negligence was of greater magnitude and constituted the efficient cause of the accident.

Specific Circumstances Connected to the Collision

• Evidence showed a discrepancy regarding the number of passengers, but all indications confirmed that the jeepney was overloaded.
• Testimonies indicated that the jeepney was parked improperly—its position on the road (partly on asphalt and partly on the shoulder) contributed to the accident.
• The tractor-trailer’s speed and direction (coming from Mahabang Ludlod) compounded the collision’s unfortunate outcome.
• The case involved discussions on the “last clear chance” doctrine, which was applied by the lower courts to allocate liability between the truck driver and the jeepney operator, despite both being negligent to varying degrees.

Issue:

Liability of the Carrier

• Whether the jeepney driver and its owners, despite evidence of their negligence in improperly parking the vehicle, should be held liable for the injuries and deaths of the passengers under the contractual obligation to transport them safely.
• Whether the legal presumption of negligence imposed on carriers (as provided by the New Civil Code) should mandate their liability despite contributory negligence on the part of the truck driver.

Proper Application of the “Last Clear Chance” Doctrine

• Whether the “last clear chance” doctrine, typically used in cases of collisions between vehicles, is appropriate for determining liability in a suit brought by passengers who are entrusting their safety to a carrier.
• Whether it is equitable to exempt the negligent party (the jeepney operator) on the ground that the accident was primarily caused by the truck driver’s negligence.

Assessment of Damages and Joint and Several Liability

• Whether the judgment should extend the remedy to include joint and several liability of both parties—the truck operators and the jeepney operators—for the acts of negligence that led to the resultant damages.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)