Case Digest (G.R. No. 170631) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On July 13, 2000, Jesmariane R. Reyes was struck by a Mitsubishi L‐300 van (plate no. PKM 195) on Sampaguita Street, Parañaque City. The van, driven by Jimmy Bautista, swerved to avoid another vehicle and fatally injured Reyes, who died two days later despite hospitalization. The van’s Certificate of Registration named Caravan Travel and Tours International, Inc. (Caravan) as owner, and Bautista was its service driver. Reyes’s aunt and custodian, Ermilinda R. Abejar, filed a complaint for damages in the Regional Trial Court (RTC) of Parañaque, naming Bautista and Caravan as defendants. Summons could not be served on Bautista, who was dropped from the case. The RTC found Bautista grossly negligent, held Caravan solidarily liable, and awarded actual, moral, exemplary damages, attorney’s fees, and costs. The RTC denied Caravan’s motion for reconsideration. The Court of Appeals affirmed with modification—reducing moral damages, awarding death indemnity, and adjusting interest rates— Case Digest (G.R. No. 170631) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Accident and Immediate Aftermath
- On July 13, 2000, Jesmariane R. Reyes was walking along Sampaguita Street, Parañaque City, when a Mitsubishi L-300 van (plate PKM 195) swerved and struck her to avoid oncoming traffic.
- The driver, Jimmy Bautista, loaded Reyes into the van but left her there instead of taking her to a hospital; a civilian later transported her to the hospital, where she died two days later.
- Parties and Procedural History
- The van’s registered owner was Caravan Travel and Tours International, Inc. (“Caravan”); Bautista was its service driver and employee.
- Ermilinda R. Abejar (Reyes’s paternal aunt and substitute parental custodian) filed a quasi-delict complaint in RTC Branch 258, Parañaque City, against Bautista and Caravan.
- The RTC dropped Bautista for lack of service, found gross negligence, and awarded P35,000 actual damages, P300,000 moral damages, P30,000 exemplary damages, P50,000 attorney’s fees, and costs.
- The Court of Appeals affirmed with modifications: reduced moral damages to P200,000; added P50,000 death indemnity; adjusted interest rates; denied Caravan’s reconsideration.
- Caravan elevated the case to the Supreme Court via Petition for Review on Certiorari, contesting Abejar’s standing, employer liability, due diligence, damages awards, and solidarity liability.
Issues:
- Whether Ermilinda R. Abejar is a real party in interest entitled to sue for Reyes’s death.
- Whether Caravan is vicariously liable as employer under Article 2180 of the Civil Code.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)