Case Digest (G.R. No. 198627)
Facts:
In DST Movers Corporation v. People’s General Insurance Corporation (G.R. No. 198627, January 13, 2016), PGIC, subrogated to the rights of Fidel Yuboco, filed a Complaint for Sum of Money (Civil Case No. 181900, MTC Manila, Br. 22) against DST Movers for ₱90,000 actual damages, interest, attorney’s fees and costs. PGIC alleged that at about 10:30 p.m. on February 28, 2002, along the South Luzon Expressway in Bilibid, Muntinlupa City, an Isuzu Elf truck (plate UAL-295) owned by DST Movers struck the rear of a stopped Honda Civic sedan (plate URZ-976) insured by PGIC, pushing it into a Mitsubishi Lancer, after which the truck fled the scene. As proof, PGIC relied chiefly on a Traffic Accident Investigation Report prepared by PO2 Cecilio Grospe Tomas, which recounted an eyewitness account by “G. Simbahon of PNCC/SLEX.” DST Movers answered, admitting ownership of the truck but asserting it was undergoing repairs on the accident date, and attached repair invoices and receipts. The MTCase Digest (G.R. No. 198627)
Facts:
- Accident and Insurance Claims
- On February 28, 2002 at about 10:30 p.m., along the South Luzon Expressway (SLEX) in Bilibid, Muntinlupa City, an Isuzu Elf truck bearing plate no. UAL-295 allegedly struck the rear of a Honda Civic sedan (plate URZ-976) that was stopped, causing it to collide with a Mitsubishi Lancer (plate CMM-373); the truck fled the scene.
- The sedan was insured under PGIC Policy No. HAL-PC-1314. Its registered owner, Fidel Yuboco, filed a total loss claim of ₱320,000 which PGIC paid in full. PGIC then subrogated to Yuboco’s rights and demanded from DST Movers Corporation (“DST Movers”), as owner of the truck, the difference of ₱90,000 (₱320,000 less the salvage value of ₱230,000).
- Key Evidence and Parties’ Contentions
- PGIC attached as its principal evidence a Traffic Accident Investigation Report (Report) prepared by PO2 Cecilio Grospe Tomas of the Muntinlupa City Traffic Enforcement Unit. The Report was based solely on the account of an unnamed reporter (“G. Simbahon of PNCC/SLEX”) and not on the personal knowledge of PO2 Tomas.
- DST Movers admitted ownership of the truck but contended that it was undergoing repairs and maintenance on February 28, 2002, attaching invoices and receipts (Annexes 1 to 1-F) to prove the vehicle was out of service.
- Trial and Appellate Proceedings
- Before the Metropolitan Trial Court (MTC) of Manila (Civil Case No. 181900), decided under the Revised Rule on Summary Procedure, DST Movers was held liable to pay PGIC ₱90,000 as actual damages plus 12% interest per annum from complaint filing, ₱10,000 attorney’s fees, and costs of suit.
- Branch 47 of the Regional Trial Court (RTC) of Manila affirmed the MTC Decision in toto.
- The Court of Appeals (CA), Former Twelfth Division, in CA-G.R. SP No. 109163, affirmed with modification: it deleted the award of actual damages and instead imposed temperate damages of ₱25,000; it denied DST Movers’ motion for reconsideration.
- DST Movers filed a Petition for Review on Certiorari under Rule 45, urging that its liability was not proven by a preponderance of evidence and that the Report was improperly admitted hearsay.
Issues:
- Was DST Movers’ liability for the February 28, 2002 collision established by a preponderance of evidence?
- Did the trial court err in admitting and giving weight to the Traffic Accident Investigation Report as an exception to the Hearsay Rule?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)