Case Digest (G.R. No. 82233) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Baritua and Bitancor vs. Court of Appeals and Nacario, G.R. No. 82233, decided on March 22, 1990 under the 1987 Constitution, petitioners Jose Baritua and Edgar Bitancor, owners and operators of JB Bus No. 80, were sued by respondents Nicolas and Victoria Nacario before the Court of First Instance of Camarines Sur after an accident on November 7, 1979 at Barangay San Cayetano, Baao, Camarines Sur. The collision between the bus driven by Bitancor and a tricycle driven by Bienvenido Nacario caused the latter’s death and damage to his vehicle. No criminal case ensued. On March 27, 1980, petitioners and the bus insurer, Philippine First Insurance Company, concluded an extrajudicial settlement with Bienvenido’s widow, Alicia Baracena Vda. de Nacario, who received ₱18,500.00 and executed a Release of Claim and affidavit of desistance. Nearly two years later, on September 2, 1981, the deceased’s parents filed a separate complaint alleging breach of an oral promise to compensate them Case Digest (G.R. No. 82233) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Accident and Immediate Aftermath
- On November 7, 1979, a tricycle driven by Bienvenido Nacario collided with JB Bus No. 80 driven by petitioner Edgar Bitancor and owned by petitioner Jose Baritua along the national highway at Brgy. San Cayetano, Baao, Camarines Sur.
- The accident resulted in the death of Bienvenido and his passenger, and damage to the tricycle. No criminal case was filed.
- Extrajudicial Settlement with Widow
- On March 27, 1980, petitioners and the bus insurer (Philippine First Insurance Co., Inc.) paid Bienvenido’s widow, Alicia Baracena Vda. de Nacario, ₱18,500.00.
- Alicia executed a Release of Claim in favor of petitioners and PFICI, discharging all actions, claims, and demands arising from the accident, and an affidavit of desistance from any civil or criminal case.
- Civil Proceedings by the Parents
- On September 2, 1981, Bienvenido’s parents, Nicolas and Victoria Ronda Nacario, filed a complaint for damages before the Court of First Instance of Camarines Sur, alleging promise of indemnification at the vigil and praying for:
- ₱25,000.00 for death;
- ₱10,000.00 for tricycle damage;
- ₱25,000.00 compensatory and exemplary damages;
- ₱5,000.00 attorneys’ fees; and moral damages.
- The RTC dismissed the complaint, ruling that payment to the widow and heir extinguished petitioners’ liability. The parents appealed.
- Court of Appeals Decision and Subsequent Petition
- The CA reversed the RTC, holding the release by Alicia did not bind the parents in their own capacity and awarded ₱20,505.00 plus attorneys’ fees.
- Petitioners’ motion for reconsideration was denied. They filed a petition for review on certiorari before the Supreme Court.
Issues:
- Whether the Court of Appeals erred in holding petitioners liable to Bienvenido’s parents despite the extrajudicial settlement and release executed by the widow.
- Whether Bienvenido’s parents, not being compulsory heirs in priority to the widow and child, could validly claim damages from petitioners after settlement with Alicia.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)