Case Digest (G.R. No. L-20455)
Facts:
- Nazario Catuiza is the petitioner against the People of the Philippines and the Honorable Court of Appeals.
- The incident occurred on August 10, 1957, involving two Halili Transit buses, Nos. 187 and 606, on an educational trip to Nueva Ecija.
- The weather was rainy, and the roads were wet.
- While traveling between kilometers 99 and 100 of the National Highway, bus 606, driven by Catuiza, collided with a jeepney coming from the opposite direction.
- The collision resulted in the deaths of eight individuals and serious injuries to two others, all passengers in the jeepney.
- Catuiza was convicted of multiple homicide and serious physical injuries due to reckless negligence in the Court of First Instance of Nueva Ecija.
- He received an indeterminate sentence of six months to six years and was ordered to indemnify the victims' heirs.
- The Court of Appeals affirmed the conviction, prompting Catuiza to appeal the ruling.
Issue:
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Ruling:
- The Court ruled that the collision and its consequences are attributable to Nazario Catuiza due to his reckless negligence.
- The Court held that sums paid by insurance companies and financial aid should not be deducted from the awarded damages.
- Loss of earning capacity can be awarded to the heirs of the deceased, regardless of their dependency status.
- The Court found no merit in reducing the damages awarded, as the absence of ma...(Unlock)
Ratio:
- The Court of Appeals determined that Catuiza's reckless negligence was the proximate cause of the accident, as he was speeding and swerved into the opposite lane.
- The defense's claim of the jeepney being overloaded and the driver at fault was dismissed due to lack of evidence supporting contributory negligence.
- Artic...continue reading
Case Digest (G.R. No. L-20455)
Facts:
The case involves Nazario Catuiza as the petitioner and the People of the Philippines along with the Honorable Court of Appeals as respondents. The events transpired on August 10, 1957, when two Halili Transit buses, Nos. 187 and 606, departed from Manila for an educational trip to the Central Luzon Agricultural College in Nueva Ecija. The weather was rainy, and the roads were wet. While traveling between kilometers 99 and 100 of the National Highway towards Cabanatuan, bus 606, driven by Catuiza and following bus 187, collided with a jeepney coming from the opposite direction. This tragic incident resulted in the deaths of eight individuals and serious injuries to two others, all of whom were passengers in the jeepney.
The case was initially heard in the Court of First Instance of Nueva Ecija, where Catuiza was convicted of multiple homicide and multiple serious physical injuries due to reckless negligence. He was sentenced to an indeterminate penalty ranging from six months of arresto mayor to six years of prision correccional, and he was ordered to indemnify the heirs of the deceased and the injured parties with specified amounts. The Court of Appeals affirmed this decision, leading Catuiza to appeal the ruling, raising several questions regarding the liability and the damages awarded.
Issue:
- Is the collision and its consequences attributable to Nazario Catuiza?
- Should the sums paid by insurance companies and financial aid given to the heirs of the victims be deducted from the awarded damages?
- Can loss of earning capacity be awarded to the heirs of the deceased if they were not dependent on the deceased for support?
- Should the damag...