G.R. No. 161803 - Dy Teban Trading, Inc. vs. Ching

Petitioner Dy Teban Trading, Inc. owned a Nissan van driven by Rogelio Ortiz with helper Romeo Catamora.
Private respondents Liberty Forest, Inc. owned a prime mover with trailer driven by Cresilito M. Limbaga.
A Joana Paula passenger bus was also involved in the incident but was not a party in the case.

On July 3, 1995, around 10:00 p.m., the prime mover with trailer suffered a tire blowout.
Limbaga parked the prime mover askew on the national highway in Barangay Sumilihon, Butuan City; its left wheels remained on the cemented highway while the right wheels rested on the sand and gravel shoulder, effectively occupying the lane of the passenger bus.
The prime mover was not equipped with the required triangular reflectorized plates (early warning devices). Limbaga placed banana trunks with leaves and, allegedly, kerosene lighted tin cans as substitutes for warning devices.
The next morning, at approximately 4:45 a.m., Ortiz was driving the Nissan van and approached the area where the prime mover was parked.
To avoid hitting the prime mover, the passenger bus swerved into the lane of the oncoming Nissan van. Ortiz swerved left to avoid the bus but the van collided with the front of the prime mover. The bus hit the rear of the prime mover.
Ortiz and his helper suffered minor injuries; the van was rendered inoperable.
SPO4 Teofilo Pame conducted the police traffic incident investigation.

On October 31, 1995, Dy Teban Trading, Inc. filed a complaint for damages against Liberty Forest, Inc., Limbaga, and Jose Ching before the Regional Trial Court (RTC) in Butuan City.
Jose Ching and the passenger bus were dismissed or absolved of liability during proceedings.
On August 7, 2001, the RTC held Liberty Forest, Inc. and Limbaga liable for damages, attorney’s fees, litigation expenses, and costs.
The RTC found Limbaga negligent for improperly parking the prime mover and not equipping it with proper warning devices.
The Court of Appeals (CA), on August 28, 2003, reversed and modified the RTC decision, absolving Liberty Forest, Inc. and Limbaga of liability. The CA ruled the proximate cause was the Nissan van driver’s failure to yield to the passenger bus.
Petitioner filed a petition for review before the Supreme Court.

Whether there were early warning devices placed on the prime mover and trailer to warn the Nissan van driver, as claimed by private respondents.
Whether the law on early warning devices should be strictly enforced to prevent similar accidents and injuries on public roads.