Title
Joseph vs. Bautista
Case
G.R. No. L-41423
Decision Date
Feb 23, 1989
A passenger's damage claim is dismissed against multiple defendants due to solidary liability after some defendants settled, with no evidence of an agreement to pursue any specific defendant.
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Case Digest (G.R. No. L-41423)

Facts:

  • Luis Joseph is the petitioner; respondents include Hon. Crispin V. Bautista, Patrocinio Perez, Antonio Sioson, Jacinto Pagarigan, Alberto Cardeno, and Lazaro Villanueva.
  • On January 12, 1973, Luis Joseph took a cargo truck owned by Patrocinio Perez, driven by Domingo Villa, from Dagupan City to Valenzuela, Bulacan for a fare of P9.00.
  • The cargo truck attempted to overtake a tricycle, while a pick-up truck, allegedly owned by Antonio Sioson and Jacinto Pagarigan and driven by Lazaro Villanueva, also attempted to overtake the cargo truck.
  • This maneuver caused the cargo truck to veer off the road and crash into a mango tree, resulting in Luis Joseph sustaining a leg fracture.
  • Luis Joseph filed a complaint for damages against Patrocinio Perez for breach of contract of carriage and against Antonio Sioson and Lazaro Villanueva for quasi-delict.
  • The case was presided over by Judge Crispin V. Bautista in the Court of First Instance of Bulacan, Branch II.
  • Defendants included Domingo Villa, who did not respond, and Rosario Vargas, who could not be served with summons.
  • Various motions and claims were filed, including a cross-claim by Perez against her co-defendants for indemnity.
  • On September 27, 1974, the respondents paid Luis Joseph P1,300.00 for his injuries, leading him to execute a release of claim against them.
  • Perez later received P7,420.61 for damages to her truck from the same respondents.
  • On July 8, 1975, Judge Bautista dismissed the case, ruling that the release of claim benefited Perez, prompting Luis Joseph to file a motion for reconsideration, which was denied.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the trial court's orders, upholding the dismissal of the case against Patrocinio Perez.
  • The Court ruled that the release of claim executed by L...(Unlock)

Ratio:

  • The Court's decision was based on the principle of solidary liability among the respondents.
  • It established that when one solidary debtor pays the entire obligation, the other solidary debtors are released from liability.
  • The Court clarified that there was only one cause of action arising from a single injury sustained by Luis Joseph, despite mult...continue reading

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