G.R. No. 85691 - Bachelor Express, Inc. vs. Court of Appeals

On August 1, 1980, Bachelor Express, Inc.’s Bus No. 800, driven by Cresencio Rivera, traveled from Davao City to Cagayan de Oro City via Butuan City.
At Tabon-Tabon, Butuan City, the bus picked up an additional passenger. Approximately fifteen minutes later, a passenger at the rear suddenly stabbed a PC soldier, triggering panic and commotion among the occupants.
When the bus stopped, passengers Ornominio Beter and Narcisa Rautraut were found lying on the roadside; Beter was already dead from head injuries, and Rautraut later died of severe injuries. The assailant fled but was killed by police.

Heirs of the deceased—Ricardo and Sergia Beter (parents of Ornominio) and Teofilo and Zoetera Rautraut (parents of Narcisa)—filed a complaint for “sum of money” against Bachelor Express, its alleged owner Samson Yasay, and driver Rivera.
Petitioners denied liability, contending the deaths resulted from the willful act of a third party and that the victims jumped off voluntarily, beyond petitioners’ control. They invoked force majeure and denied negligence.
The Regional Trial Court (Branch I, Butuan City) dismissed the complaint, ruling that petitioners were not insurers and had exercised due diligence.
On appeal, the Court of Appeals reversed and set aside the dismissal, finding petitioners jointly and solidarily liable to pay P75,000 to the heirs of Ornominio Beter and P45,000 to the heirs of Narcisa Rautraut, plus costs and attorney’s fees.
Petitioners sought relief via a petition for review on certiorari to the Supreme Court, challenging the CA’s findings of fact and law and the award of damages.

Whether petitioners, as common carriers, may be held liable for the death of passengers who jumped from a running bus in panic.
Whether petitioners overcame the presumption of negligence under Article 1756 of the Civil Code by proving extraordinary diligence or force majeure.
Whether the Court of Appeals’ factual findings—bus speed, door operation, driver’s response, and equipment deficiencies—establish petitioners’ negligence.
Whether the private respondents had legal personality as heirs to maintain the action.
Whether the amounts awarded by the Court of Appeals for loss of earnings, moral damages, death indemnity, and attorney’s fees are supported by evidence and jurisprudential standards.