Facts:

On January 12, 1958, a tragic incident occurred in Taal, Batangas, when a passenger jeepney, owned by spouses Pedro Gahol and Luisa Alcantara, was parked on the road. The jeepney, driven by Pepito Buno, was on its regular route and had exceeded its maximum capacity of eleven passengers, carrying fourteen to sixteen individuals at the time. After crossing a bridge, Buno stopped the jeepney to allow a passenger to alight. However, he parked the vehicle in such a manner that half of it was on the asphalted pavement, creating a hazardous situation. Approximately five minutes later, a speeding water truck, owned by Anselmo Maligaya and Ceferina Aro and driven by Guillermo Itazon, collided violently with the parked jeepney from behind, causing it to overturn into a nearby ditch. This collision resulted in the deaths of three passengers and injuries to two others, necessitating their hospitalization. In February 1958, the representatives of the deceased and injured passengers filed ...

Facts:

Background of the Incident

• On January 12, 1958, at noon, a passenger jeepney was parked along the road to Taal, Batangas.
• The jeepney was carrying more passengers than its legal capacity, being overloaded as it had a maximum capacity of eleven persons (including the driver) yet was transporting fourteen to sixteen passengers.
• The jeepney was parked partially on the asphalted road and partially on the shoulder when it stopped to allow a passenger to alight.

Description of the Collision

• Approximately five minutes after parking, a motor truck—described as speeding and under the control of its driver—collided violently with the rear of the jeepney.
• The truck, which was coming from the direction of Mahabang Ludlod and bearing plate No. T-17526, struck the jeepney with considerable force, causing it to overturn into a nearby ditch.
• The collision resulted in the death of three jeepney passengers and injured two others, who required prolonged hospitalization at the Provincial Hospital.

Parties Involved and Previous Proceedings

• The case arose from suits filed in February 1958 by representatives of the dead and injured passengers seeking compensation for consequential damages.
• The suits implicated both the driver and the owners of the truck and the jeepney.
• The Batangas court of first instance absolved the jeepney driver and its owners, holding the truck driver and its owners liable.
• On appeal, the Court of Appeals affirmed the exoneration of the jeepney parties despite observing that the jeepney driver was negligent in parking his vehicle improperly.

Judicial Findings and Testimonies

• Evidence presented revealed that the jeepney was overloaded and parked with a significant part of its wheels off the designated roadway, contributing to the accident's severity.
• Testimonies from the parties indicated discrepancies regarding the number of passengers, but the fact of overloading remained undisputed.
• The truck driver was adjudged to have been more culpably negligent; however, his greater negligence did not automatically preclude liability on the part of the jeepney driver and its owners.

Issue:

Determination of Liability

• Whether the negligence of the jeepney driver, evidenced by his improper parking and overloading the vehicle, should render him and the owners liable for the injuries and deaths sustained by the passengers.
• Whether absolving the jeepney parties based on the “last clear chance” doctrine is appropriate when a carrier’s contractual obligation to ensure passenger safety is at issue.

Application of the “Last Clear Chance” Doctrine

• Whether the doctrine may be used to mitigate or share liability between the parties involved, particularly when both parties exhibited elements of negligence.
• Whether the doctrine can be invoked in a suit brought by passengers against their carrier, as opposed to conflicts between colliding vehicles.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)