Case Digest (G.R. No. L-21486) Core Legal Reasoning Model
Facts:
The case involves La Mallorca and Pampanga Bus Company, Inc., also known as La Mallorca-Pambusco, as petitioners, and Valentin de Jesus and Manolo Tolentino as respondents. The dispute arose from a tragic accident that occurred on October 8, 1959, in a barrio in Marilao, Bulacan. The accident involved a head-on collision between a bus operated by the petitioner and a freight truck traveling in the opposite direction. The fatality was Lolita de Jesus, the 20-year-old daughter of Valentin de Jesus and wife of Manolo Tolentino, who was a passenger on the bus. The immediate cause of the accident was the sudden explosion or blowout of the left front tire of the bus, which caused the driver to lose control. The lower court, the Court of First Instance of Bulacan in Civil Case No. 2100, ruled in favor of the plaintiffs (respondents) and sentenced the petitioner bus company to pay actual damages amounting to ₱2,132.50, compensatory damages of ₱14,400.00, moral damages of ₱10,000.00 to
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Case Digest (G.R. No. L-21486) Expanded Legal Reasoning Model
Facts:
- Parties Involved
- Petitioners: La Mallorca and Pampanga Bus Company, Inc. (La Mallorca-Pambusco)
- Respondents: Valentin de Jesus and Manolo Tolentino (plaintiffs in the civil suit)
- Origin of the Case
- The case arose from a fatal accident on October 8, 1959, in a barrio in Marilao, Bulacan.
- Lolita de Jesus, daughter of Valentin de Jesus and wife of Manolo Tolentino, was a passenger aboard the La Mallorca-Pambusco bus.
- The bus collided head-on with a freight truck traveling in the opposite direction.
- The immediate cause was the sudden blowout of the left front tire of the bus, which caused the bus driver to lose control.
- Lower Courts’ Decisions
- The Court of First Instance of Bulacan, in Civil Case No. 2100, ruled in favor of the plaintiffs.
- The defendants (La Mallorca-Pambusco) were ordered to pay:
- ₱2,132.50 as actual damages
- ₱14,400.00 as compensatory damages
- ₱10,000.00 each to the plaintiffs as moral damages
- ₱3,000.00 as attorney’s fees
- The Court of Appeals affirmed the decision of the trial court.
- Petitioners’ Arguments on Appeal
- The tire blowout was a fortuitous event (caso fortuito) and thus exonerated them from liability.
- The Court of Appeals erred in imposing moral damages.
- They cited earlier Court of Appeals rulings in Rodriguez vs. Red Line Transportation Co. and People vs. Palapad, where tire blowouts were considered fortuitous events.
- Findings on the Cause of the Blowout
- The inner tube of the left front tire was found pressed between the inner circle of the wheel and a rim that had slipped out.
- This indicated a mechanical defect or fault in the bus equipment.
- The defect was deemed easily discoverable with a more thorough inspection before the trip.
- The bus was traveling at a high speed immediately before the accident.
- The tire was not new but described as “not so very worn out” (hindi masyadong kalbo).
Issues:
- Whether the tire blowout was a fortuitous event (caso fortuito) that absolves the bus company from liability.
- Whether moral damages are recoverable by the plaintiffs arising from the death of a passenger due to breach of contract by a common carrier.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)