G.R. No. L-61311 - Villanueva vs. Castaneda, Jr.

On April 1, 1999 at around 9:00 p.m., Capt. Renato Octaviano, his mother Wilma, and sister Janet rode a tricycle driven by Eduardo Y. Padilla along Naga Road, Las Piñas City. Renato asked his mother for change for his P10 fare.
A car driven by Al Dela Cruz (petitioner), approaching at high speed with bright headlights, struck the rear portion of the tricycle. The impact flipped the tricycle, throwing Renato onto the gutter and rendering him unconscious.

Bystanders, including S/Sgt. Joselito Lacuesta and Antonio Fernandez, assisted Renato, noting petitioner appeared intoxicated. The injured were first brought to petitioner’s house briefly, then to a clinic, but eventually to Perpetual Help Medical Center, where Renato’s right leg was amputated below the knee.
Renato underwent nine months of rehabilitation at V. Luna General Hospital, treatment for bone infection at Fort Bonifacio Hospital, and later fitted with a prosthesis at his expense. Total medical and prosthetic expenses amounted to ₱623,268.00.

Renato and Wilma Octaviano filed a civil case for damages against petitioner and the car owner, Dr. Isagani Cirilo. Witnesses for respondents testified to petitioner’s negligent and drunk driving. Petitioner claimed the tricycle suddenly accelerated from a stop in front of a parked van.
The Regional Trial Court (RTC), Branch 275, Las Piñas City, on February 24, 2009, dismissed respondents’ claim, finding petitioner credible, not negligent, and holding the tricycle driver and respondents contributorily negligent for ordinance violations. It also exonerated the car owner.

Respondents appealed. On January 30, 2014, the Court of Appeals (CA) reversed the RTC, finding petitioner negligent and in violation of R.A. No. 4136 (drunk driving). It held petitioner and the car owner solidarily liable.
The CA awarded respondents actual, moral, and exemplary damages, and attorney’s fees, distributing amounts as follows:

Wilma: medical (₱1,500), hospital (₱1,450), transportation (₱6,000), moral damages (₱50,000), exemplary damages (₱20,000)
Renato: hospital (₱369,354), medical (₱60,462.23), loss of income (₱90,000), moral damages (₱100,000), exemplary damages (₱20,000)
Attorney’s fees: ₱100,000

Petitioner sought review under Rule 45, raising factual issues: CA’s negligence finding; unsupported factual findings; misplacement of proximate cause on petitioner; overlooked uncontroverted facts.
He denied intoxication, challenged the police report’s admissibility for lack of confrontation, and blamed the tricycle driver. Respondents maintained the issues were factual and CA was correct.

Whether petitioner was negligent in the operation of his vehicle.
Whether the CA’s factual findings on negligence are supported by the evidence.
Whether the proximate cause of the accident was the fault of the tricycle driver, not petitioner.
Whether the CA overlooked undisputed facts that would alter the outcome.