Case Digest (G.R. No. 170813)
Facts:
The case involves B.F. Metal Corporation as the petitioner and Spouses Rolando M. Lomotan, Linaflor Lomotan, and Rico Umuyon as the respondents. The incident occurred on May 3, 1989, in Cainta, Rizal, when Rico Umuyon was driving a jeep owned by the Lomotans. While traveling at a moderate speed of 20 to 30 kilometers per hour along Felix Avenue, a ten-wheeler truck driven by Onofre V. Rivera, an employee of B.F. Metal Corporation, overtook another vehicle and collided with Umuyon's jeep, resulting in significant damage to the jeep and severe injuries to Umuyon. The injuries included multiple rib fractures and a fractured scapula, necessitating a 19-day hospitalization. Following the accident, Umuyon’s ability to earn was diminished, reducing his daily income from P150.00 to P100.00.
On October 27, 1989, the respondents filed a civil action for damages against B.F. Metal Corporation and Rivera in the Regional Trial Court (RTC) of Antipolo, Rizal. The complaint alleged g...
Case Digest (G.R. No. 170813)
Facts:
1. The Accident:
- On May 3, 1989, respondent Rico Umuyon was driving an owner-type jeep owned by Spouses Rolando and Linaflor Lomotan along Felix Avenue in Cainta, Rizal.
- The jeep was traveling at a moderate speed of 20 to 30 kilometers per hour.
- A ten-wheeler truck, driven by Onofre Rivera and owned by petitioner BF Metal Corporation, overtook a car by invading the opposite lane and collided with the jeep.
- The jeep was completely wrecked, and Umuyon suffered severe injuries, including blunt thoracic injury, multiple rib fractures, and a fractured scapula, requiring 19 days of hospitalization.
- Umuyon’s injuries rendered him unable to drive, reducing his daily income from P150.00 to P100.00.
2. Legal Proceedings:
- On October 27, 1989, respondents filed a civil action for damages against BF Metal Corporation and Rivera, alleging gross negligence and recklessness on the part of Rivera and failure of BF Metal to exercise due diligence in supervising its employees.
- The complaint sought actual, exemplary, and moral damages, as well as attorney’s fees.
- BF Metal and Rivera denied the allegations, claiming that Umuyon was solely at fault and that BF Metal had exercised due diligence in selecting and supervising its employees.
3. Trial Court Decision:
- The Regional Trial Court (RTC) found Rivera negligent for failing to ensure the opposite lane was clear before overtaking and held BF Metal liable for negligence in supervising its employees.
- The RTC awarded actual damages (P96,700.00 for the jeep, P15,000.00 for medical expenses, and P50,000.00 for lost earnings), moral damages (P100,000.00), exemplary damages (P100,000.00), and attorney’s fees (P25,000.00 plus P1,000.00 per court appearance).
4. Court of Appeals Decision:
- The Court of Appeals affirmed the RTC’s finding of negligence but modified the damages awarded.
- The appellate court increased the repair cost of the jeep to P130,655.00, reduced medical expenses to P10,167.99, and adjusted lost earnings to P2,850.00.
- Moral and exemplary damages were maintained at P100,000.00 each, and attorney’s fees were upheld.
5. Supreme Court Petition:
- BF Metal filed a petition for review, challenging only the damages awarded by the Court of Appeals.
- The issues raised were: (1) whether the actual damages based on a job estimate should be reduced, (2) whether Spouses Lomotan are entitled to moral damages, and (3) whether exemplary damages and attorney’s fees were warranted.
Issue:
Actual Damages:
- Whether the amount of actual damages based on a job estimate should be reduced.
- Petitioner argued that the repair cost of P130,655.00 was speculative and not supported by actual receipts.
Moral Damages:
- Whether Spouses Lomotan are entitled to moral damages.
- Petitioner contended that only Umuyon, who suffered physical injuries, should be awarded moral damages.
Exemplary Damages and Attorney’s Fees:
- Whether the award of exemplary damages and attorney’s fees was justified.
- Petitioner argued that exemplary damages should only be awarded if moral damages are granted.
Ruling:
Actual Damages:
- The Supreme Court reduced the actual damages for the jeep from P130,655.00 to P72,000.00, based on the acquisition cost shown in the Deed of Sale.
- The Court held that job estimates alone are insufficient to prove actual damages and that the best evidence is the acquisition cost of the jeep.
Moral Damages:
- The Court awarded P30,000.00 in moral damages to Umuyon but denied moral damages to Spouses Lomotan.
- The Court ruled that moral damages are recoverable only by the party who suffered physical injuries or psychological harm, and Spouses Lomotan did not provide sufficient proof of such harm.
Exemplary Damages and Attorney’s Fees:
- The Court affirmed the award of exemplary damages (P100,000.00) and attorney’s fees (P25,000.00).
- The Court held that exemplary damages are warranted in cases of gross negligence, and attorney’s fees are recoverable when exemplary damages are awarded.
Ratio:
Actual Damages:
- Actual damages must be proven with reasonable certainty and supported by competent evidence, such as receipts or other documentation.
- Job estimates alone are insufficient to prove actual damages, as they are speculative and do not reflect actual expenses incurred.
Moral Damages:
- Moral damages are recoverable only in specific cases, such as physical injuries or psychological harm, and must be proven with factual and legal justification.
- Spouses Lomotan failed to prove that they suffered psychological harm or other injuries entitling them to moral damages.
Exemplary Damages and Attorney’s Fees:
- Exemplary damages are awarded to serve as a deterrent and are justified in cases of gross negligence.
- Attorney’s fees may be awarded when exemplary damages are granted, as provided under Article 2208 of the Civil Code.
Conclusion:
The Supreme Court partially granted the petition, reducing the actual damages for the jeep to P72,000.00 and awarding moral damages of P30,000.00 solely to Umuyon. The awards of exemplary damages and attorney’s fees were affirmed. The Court emphasized the need for competent proof of actual damages and the limited scope of moral damages in cases of quasi-delict.