G.R. No. 76353 - Alcuaz vs. Philippine School of Business Administration

Filipinas Synthetic Fiber Corporation (Filsyn) is the petitioner and owner of the shuttle bus involved in the accident.
The respondents are Wilfredo de los Santos, Benito Jose de los Santos, Maria Elena de los Santos, and Carmina Vda. de los Santos, whose family members were affected by the accident.
Alfredo S. Mejia, an employee of Filsyn, was driving the shuttle bus at the time of the incident.

On the night of September 30, 1984, Teresa Elena Legarda-de los Santos, wife of respondent Wilfredo de los Santos, was performing at the Rizal Theater in Makati City as part of the play “Woman of the Year.”
Following her performance, at Wilfredo’s request, his brother Armando de los Santos (husband of respondent Carmina Vda. de los Santos) drove the company car—a 1980 Mitsubishi Galant Sigma (Plate No. NSL 559)—to fetch Teresa Elena.
Annabel Vilches and Jerome Macuja, fellow cast members, joined Teresa Elena in the Galant Sigma.
Around 11:30 p.m., while traveling along Katipunan Road (White Plains), the Galant Sigma collided with Filsyn’s shuttle bus, which was driven by Alfredo S. Mejia.

The collision caused the Galant Sigma to be dragged approximately 12 meters across the White Plains Road, close to Camp Aguinaldo, where the vehicle burst into flames, resulting in the death by incineration of all four occupants.
A criminal charge of reckless imprudence resulting in damage to property with multiple homicide was filed against Mejia; the criminal proceedings favored Mejia.
Separate civil actions for damages were instituted by the family of Annabel and by Wilfredo and Carmina, along with their minor children, which were later consolidated in the Regional Trial Court (RTC).

The RTC rendered a decision ordering Filsyn and Mejia to jointly and severally pay various sums in actual, compensatory, moral, and attorney’s fees to the families of the deceased Teresa Elena and Armando de los Santos.

Specific amounts were awarded for actual damages, compensatory damages (interpreted as unrealized income and loss of financial support), moral damages, and attorney’s fees.
The RTC decision was later modified by the Court of Appeals (CA) regarding the compensatory damages and unrealized income awards in the two separate civil cases.

Alfredo S. Mejia was negligent, having driven at 70 kilometers per hour, exceeding the allowable speed limit under Section 35 of RA 4136.
Filsyn failed to exercise the due diligence required in the selection and supervision of its employee, thereby incurring vicarious liability under Article 2180 of the New Civil Code.

Following the denial of its motion for reconsideration, Filsyn elevated the dispute by filing a Petition for Review under Rule 45, assailing:

The finding of negligence on the part of Mejia.
The conclusion that Filsyn did not observe the due diligence of a “good father of a family” in hiring and supervising its employee.
The amounts computed as damages not conforming with the evidence on record.

Filsyn argued that the CA’s findings that Mejia was negligent were not supported by the evidence, contending that the accident’s circumstances pointed also to negligence on the part of the driver of the Galant Sigma.
The petitioner maintained that it had exercised due diligence in selecting and supervising its employees, submitting documentary proofs and testimony regarding Mejia’s qualifications and supervisory practices.
Filsyn claimed that the computed award for compensatory damages and moral damages was excessive and not supported by a preponderance of evidence, particularly noting that moral damages in similar cases were typically fixed at a lower amount.

Alfredo S. Mejia, while driving the shuttle bus, was negligent by exceeding the prescribed speed limit and thereby causing the collision.
Filsyn did not exercise the due diligence required in the selection and proper supervision of its employee, which is mandated to fend off vicarious liability under Article 2180 of the New Civil Code.

Whether the damages awarded by the Court of Appeals (especially the compensatory and moral damages) were supported by the evidence on record or if they should be revised in light of the evidence regarding the salaries and losses of the deceased victims.
Whether the findings as to the negligence of the drivers and the corresponding assignment of liability should be re-evaluated given that questions of fact are generally not reviewable in a petition for review on certiorari.