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 mon...

Facts:

1. Incident Overview:

   • On August 10, 1957, two Halili Transit buses (Nos. 187 and 606) carrying students and professors from Araneta University and Far Eastern University were on an educational trip to Nueva Ecija.
   • The weather was rainy, the road was wet, and visibility was poor.
   • Between kilometers 99 and 100 of the National Highway leading to Cabanatuan, bus 606, driven by Nazario Catuiza, collided with a jeep coming from the opposite direction.
   • The collision resulted in the death of eight persons and serious injuries to two others, all passengers of the jeep.

2. Prosecution’s Version:

   • Bus 606 was traveling at over 70 kilometers per hour.
   • The bus swerved to the left, crossing the center line by about one meter, in an attempt to overtake bus 187.
   • The bus hit the jeep on its left side, throwing it to the west shoulder of the road near a canal.
   • The bus continued to slide and eventually landed on its left side in the canal, 40 paces from the point of impact.

3. Defense’s Version:

   • The defense claimed that the jeep, driven by a woman, was traveling at 50 miles per hour and attempted to overtake a freight truck ahead of it.
   • The defense argued that the jeep collided with bus 606 due to its own actions.

4. Trial Court Decision:

   • Nazario Catuiza was convicted of multiple homicide and multiple serious physical injuries through reckless negligence.
   • He was sentenced to an indeterminate penalty of six months of arresto mayor to six years of prision correccional.
   • He was also ordered to indemnify the heirs of the deceased and the injured parties, with subsidiary imprisonment in case of insolvency.

5. Court of Appeals Decision:

   • The Court of Appeals affirmed the trial court’s decision, holding that the proximate cause of the accident was Catuiza’s reckless negligence.

Issue:

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Ruling:

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Ratio:

1. Proximate Cause:

   • The proximate cause of the accident was Catuiza’s reckless negligence in driving at excessive speed and swerving into the opposite lane.

2. Insurance Payments and Subrogation:

   • Article 2207 of the Civil Code applies only to property damages, not to damages for loss of life or personal injury. Life insurance payments are not deductible from the award.

3. Property Damage Allegations:

   • A defendant cannot be convicted of or sentenced for damages not alleged in the information.

4. Loss of Earning Capacity:

   • Under Article 2206 of the Civil Code, the heirs of the deceased are entitled to damages for loss of earning capacity, regardless of dependency.

5. Contributory Negligence:

   • Contributory negligence must be proven to have directly contributed to the accident. In this case, the alleged overloading of the jeep did not contribute to the collision.

6. Necessary and Essential Industries:

   • The law does not provide for reduced liability for damages caused by necessary and essential industries.

Final Decision

The Supreme Court modified the trial court’s decision by reducing the indemnity due to the heirs of Pedro Pagdanganan from P17,850.00 to P16,850.00. The decision was affirmed in all other respects, with costs against Nazario Catuiza.