Facts:

The case involves the Batangas Laguna Tayabas Bus Company (BLTB) and its driver Armando Pon as petitioners, against the Intermediate Appellate Court and the heirs of several deceased individuals as respondents. The incident occurred on August 11, 1978, on a highway in Barangay Isabong, Tayabas, Quezon. A collision took place between BLTB Bus No. 1046, driven by Armando Pon, and Superlines Transportation Company Bus No. 404, driven by Ruben Dasco. The collision resulted in the deaths of Aniceto Rosales, Francisco Pamfilo, and Romeo Neri, while Nena Rosales (the wife of Aniceto) and Baylon Sales sustained injuries.

The evidence presented indicated that while BLTB Bus No. 1046 was attempting to overtake a Ford Fiera car, Superlines Bus No. 404 was approaching from the opposite direction. Armando Pon made a belated attempt to slow down and return to his lane, but the buses collided. Following the incident, Nena Vda. de Rosales, Baylon Sales, and the heirs of the deceased filed...

Facts:

The Collision and Immediate Circumstances

• On August 11, 1978, a collision occurred at a highway in Barangay Isabong, Tayabas, Quezon.
• The accident involved two buses: BLTB Bus No. 1046, operated by the Batangas Laguna Tayabas Bus Company (BLTB) and driven by Armando Pon, and Superlines Bus No. 404, operated by Superlines Transportation Company and driven by Ruben Dasco.
• The collision happened as the BLTB bus attempted to overtake a Ford Fiera while negotiating an ascending bend of the highway marked by a continuous yellow strip, signifying a no-overtaking zone.

Consequences of the Collision

• Fatalities: Three passengers—Aniceto Rosales, Francisco Pamfilo, and Romeo Neri—lost their lives.
• Injuries: Passenger Nena Rosales (wife of Aniceto) and Baylon Sales sustained injuries.
• The nature of the collision and the context (an overtaking maneuver on a dangerous curve) highlighted the imprudence and recklessness involved.

Legal Actions and Proceedings

• Separate cases were instituted in the Court of First Instance of Marinduque by the surviving heirs and relatives (private respondents) of the deceased and injured. These actions sought damages, attorney’s fees, litigation expenses, and costs.
• Concurrently, criminal cases were filed in the Court of First Instance of Quezon against the drivers of the two buses.
• In their defense, BLTB, Superlines, and their drivers (Pon and Dasco) maintained that they had exercised due care and attempted to shift blame among themselves by interposing counterclaims and crossclaims.

Findings by the Trial Court

• After trial on the merits, the lower court found that:
• BLTB and its driver Armando Pon were solely responsible for the collision due to recklessness and imprudence.
• Superlines and its driver Ruben Dasco were exonerated from liability.
• The trial court’s decision held BLTB and its driver jointly and severally liable to compensate the victims for damages.

Appellate Proceedings and Issues Raised

• BLTB and Armando Pon appealed the trial court’s decision to the Intermediate Appellate Court.
• The appellate court affirmed the trial court’s ruling with modifications, including raising the death indemnity to P30,000.00 per set of the victims’ heirs, while citing that the actions of the private respondents were founded on both culpa contractual and culpa aquiliana.
• A petition for review by certiorari was subsequently filed, contending that the appellate court erred in adjudging the case solely on the premise of culpa contractual.

Contentions by the Petitioners and the Court’s Rebuttal

• Petitioners argued that if the private respondents intended to base their claims on culpa contractual (breach of contract of carriage), they could have simply impleaded BLTB and its driver. Instead, the respondents had opted for an action based on culpa aquiliana (tort).
• The court rejected the petitioners’ contention, highlighting that the evidence clearly indicated that the proximate cause of the collision was the negligence of the BLTB bus driver, a fact underpinning both contractual and delictual liability.

Issue:

• Whether the legal classification of the case should rest on culpa contractual (breach of contract of carriage) or culpa aquiliana (tort), given the nature of the claims and the evidence.
• Whether the trial and appellate courts erred in attributing the collision solely to the negligence of the BLTB driver, particularly under the premise of violating established traffic regulations.
• Whether BLTB and its driver exercised the extraordinary diligence required under the contract of carriage, especially when carrying passengers on potentially hazardous routes.
• Whether the carrier can evade liability for injuries or fatalities when it is demonstrated that the accident resulted from the sole negligence and recklessness of its employee.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)