Case Digest (G.R. No. 240066)
Facts:
Gerry S. Fegarido and Linalie A. Milan v. Almarina S. Alcantara, G.R. No. 240066, June 13, 2022, Supreme Court Second Division, Leonen, SAJ., writing for the Court.At around 6:30 p.m. on October 15, 2008, Cristina S. Alcantara was struck and thrown several meters by a public utility jeepney while crossing 25th Street, East Bajac‑Bajac, Olongapo City; she was taken to hospital and died three days later. The jeepney was driven by Gerry S. Fegarido and was registered to Linalie A. Milan. Alcantara’s heirs—represented by their attorney‑in‑fact Charlie S. Alcantara—filed a Complaint for damages in the Regional Trial Court (RTC) and sought injunctive relief; a criminal information for reckless imprudence resulting in homicide was likewise filed against Fegarido in the Municipal Trial Court in Cities (MTC).
The MTC, in a June 19, 2012 Decision, acquitted Fegarido of the criminal charge, concluding the prosecution failed to prove reckless imprudence beyond reasonable doubt, although the MTC nonetheless found civil negligence by preponderance. The RTC, in a March 9, 2015 Decision, found Fegarido negligent and Milan vicariously liable for failure in selection/supervision, and ordered them solidarily to pay actual, moral, exemplary damages, and attorney’s fees. The RTC relied on eyewitness testimony (a traffic enforcer and a security guard), a physician’s report, and testimony showing inadequate vetting of the driver.
Fegarido and Milan appealed to the Court of Appeals (CA). In its October 13, 2017 Decision, the CA affirmed the RTC’s findings of negligence and vicarious liability, reiterating that criminal acquittal does not bar an independent civil action for quasi‑delict and that the preponderance standard was satisfied. The CA denied petitioners’ motion for reconsideration in a May 4, 2018 Resolution.
Petitioners then filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court,...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in affirming the RTC’s finding that petitioner Gerry S. Fegarido was negligent?
- Did the Court of Appeals err in affirming the RTC’s finding that petitioner Linalie A. Milan is vicariously liable for Fegarido’s negligence?
- Did the Court of Appeals err in awarding actual, moral, and exemplary damages, and attorney’s fees and litig...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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