Facts:

The case revolves around the tragic incident that occurred on July 31, 1980, involving the petitioner, Baliwag Transit, Inc., and the respondents, spouses Antonio and Leticia Garcia, along with A & J Trading and its driver, Julio Recontique. Leticia Garcia, along with her five-year-old son Allan, boarded Baliwag Transit Bus No. 2036, driven by Jaime Santiago, en route to Cabanatuan City. The bus was driven at approximately 7:30 PM in Malimba, Gapan, Nueva Ecija when it collided with a cargo truck parked dangerously on the highway. The truck's left rear was protruding into the lane, and a kerosene lamp served as a warning sign. Despite the warnings from passengers for the driver to slow down, Santiago ignored them, continued to drive at a high speed, and was seen conversing with colleagues. As the bus approached the disabled truck, a significant crash ensued, resulting in the deaths of the bus driver and his helper, and injuries to multiple passengers, including Leticia a

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Facts:

Background and Initial Events

• On July 31, 1980, Leticia Garcia and her five-year-old son, Allan Garcia, boarded Baliwag Transit Bus No. 2036 bound for Cabanatuan City.
• They occupied a seat immediately behind the driver, Jaime Santiago.

Incident and Collision

• At about 7:30 in the evening in Malimba, Gapan, Nueva Ecija, the bus encountered a stationary cargo truck.
• The truck was parked at the shoulder of the national highway with its left rear portion jutting into the outer lane, and the narrow shoulder made it difficult to fully accommodate the vehicle.
• A kerosene lamp had been placed at the edge of the road on the truck as a warning device.
• The bus driver, Santiago, was driving at an inordinately fast speed under adverse conditions (drizzle and darkness) and failed to notice the truck and its warning device.
• Despite passengers urging him to slow down, he disregarded their calls.
• He was also engaged in animated conversations with co-employees while operating the bus.
• When passengers cried out "Babangga tayo!" (indicating the imminent collision), Santiago attempted to brake; however, the bus still rammed into the cargo truck.

Consequences and Casualties

• The collision resulted in the instant death of the bus driver, Santiago, and the truck's helper, Arturo Escala.
• Several passengers sustained injuries, including:
• Leticia Garcia, who suffered fractures to her pelvis and right leg, underwent emergency treatment in a provincial hospital, was later transferred to the National Orthopedic Hospital, and eventually underwent an operation for a partial hip prosthesis.
• Allan Garcia, who sustained a broken leg and received emergency treatment.

Legal Proceedings and Claims

• Spouses Antonio and Leticia Garcia initiated a suit in the Regional Trial Court of Bulacan against:
• Baliwag Transit, Inc. for breaching its contract of carriage by failing to deliver its passengers to their destination safely.
• A & J Trading and Julio Recontique, alleging that their negligence in failing to equip the cargo truck with an adequate early warning device contributed to the accident.
• The defense by the respondents involved:
• Baliwag’s assertion that the accident was solely due to the negligence of A & J Trading and its driver, Julio Recontique.
• A & J Trading and Recontique’s counterclaim that the bus driver, Santiago, was negligent and responsible for the accident.

Court Decisions and Modifications

• At the trial level, the court found all defendants liable for the accident and awarded the Garcia spouses:
• P25,000.00 for hospitalization and medication fees.
• P450,000.00 for loss of earnings over eight years (later modified).
• P2,000.00 for the hospitalization of minor Allan Garcia.
• P50,000.00 in moral damages.
• P30,000.00 in attorney’s fees.
• On appeal, the Court of Appeals modified the trial court’s decision by:
• Absolving A & J Trading from liability.
• Reducing the award of attorney’s fees to P10,000.00.
• Adjusting the loss of earnings award to P300,000.00.

Petition for Certiorari

• Baliwag Transit, Inc. subsequently filed a petition for certiorari with the Supreme Court to review the decision of the Court of Appeals.
• The central issues raised included:
• Whether the Court of Appeals erred in absolving A & J Trading from liability by holding Baliwag solely responsible for the injuries sustained by Leticia and Allan Garcia.
• Whether the amount of damages awarded to the Garcia spouses, including the modifications in damages, was correct.

Issue:

Liability Issue

• Whether the Court of Appeals erred in absolving A & J Trading from liability by attributing the entire responsibility for the mishap to Baliwag Transit.
• Whether Baliwag, as a common carrier, should be held solely liable for the injuries suffered and damages incurred by the Garcia spouses due to its failure to deliver them safely.

Damages Issue

• Whether the amounts awarded for hospitalization and medical fees, loss of earnings, moral damages, and attorney’s fees were properly calculated and supported by the evidence.
• Whether the reduction in the awards (notably the hospitalization fees and loss of earnings) made by the Court of Appeals was justified.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)