G.R. No. 160709 - Lambert vs. Heirs of Castillon

On the evening of January 13, 1991, Ray Castillon borrowed a motorcycle from his brother Joel Castillon in Tambo, Iligan City.
Ray invited his friend Sergio Labang to ride with him as backrider.
After supper and drinking a bottle of beer, Ray drove the motorcycle at high speed along the highway toward Tambo.
At Barangay Sto. Rosario, an accident occurred with a Tamaraw jeepney owned by petitioner Nelen Lambert and driven by Reynaldo Gamot, who was traveling in the same direction but made a sudden left turn.
The accident caused the instantaneous death of Ray and injuries to Sergio.

The heirs of Ray Castillon (respondents) filed a civil action for damages with prayer for preliminary attachment against petitioner Nelen Lambert, docketed as Civil Case No. 06-2086 before the RTC of Iligan City.
The complaint was amended to include Joel Castillon’s claim for damages to the motorcycle, which was later dismissed for lack of ownership.

On June 29, 1993, the RTC ruled in favor of the respondents, holding petitioner liable but reducing liability by 20% due to Ray’s contributory negligence.
The RTC ordered petitioner to pay P633,091 for loss of support, death indemnity, funeral and related expenses, moral damages, and attorney’s fees; and ordered Zenith Insurance Corporation to pay P16,500 directly to the plaintiffs.
The Court of Appeals affirmed the RTC decision on October 21, 2002.

Petitioner filed a petition for review under Rule 45 seeking reversal of the Court of Appeals decision.
Petitioner argued:

The presumption that a driver who hits the rear of another vehicle is liable should apply, citing Philippine Rabbit Bus Lines and Edna A. Raynera decisions.
The trial court erroneously treated tailgating at high speed as contributory negligence rather than proximate cause.
The trial court erred in the computation of loss of earning capacity, deviating from the Villa Rey Transit formula.
The award of moral damages lacked basis, citing Ace Haulers Corporation.
Petitioner denied liability, asserting the negligence of Ray was the proximate cause of death.

Whether the petitioner’s driver’s sudden left turn and the ensuing accident constitute negligence and proximate cause of the death of Ray Castillon.
Whether the presumption that a driver who hits the rear of another vehicle is the cause of the accident applies.
Whether Ray Castillon’s contributory negligence justifies mitigation of damages and to what extent.
Whether the computation of loss of earning capacity by the trial court complies with the formula approved by prevailing jurisprudence.
Whether the award of moral damages and attorney’s fees by the trial court is justified.