Case Digest (G.R. No. 140023)
Case Digest (G.R. No. 140023)
Facts:
Rudy Lao v. Standard Insurance Co., Inc., G.R. No. 140023, August 14, 2003, the Supreme Court Second Division, Quisumbing, J., writing for the Court.Petitioner Rudy Lao (owner) insured his Fuso truck (Plate No. FCG‑538) with respondent Standard Insurance Co., Inc. under Policy No. CV‑21074 for P200,000 plus P50,000 for goods. On April 24, 1985, at about 8:00 p.m. in Barangay Buhang, Jaro, Iloilo City, the insured truck struck another truck (Plate No. FBS‑917), also owned by petitioner, which was running ahead of it. Damages to the insured truck were estimated at about P110,692 and to the other truck and nearby properties at about P35,000.
Petitioner filed a claim with respondent, which denied it after its adjuster reportedly discovered that the driver of the insured truck, Leonardo Anit, did not have a license authorizing him to drive vehicles over 4,500 kgs., thus violating the policy’s “authorized driver” clause. The respondent relied on an entry in the police blotter that named Leonardo Anit as driver. Petitioner produced a Motor Vehicle Accident Report prepared three days later by Investigating Officer Pat. Felipe D. Villahermosa stating that another driver, Giddie Boy Y. Coyel, was driving the insured truck; Giddie Boy held a license authorizing him to drive the heavier truck. Respondent continued to deny the claim.
Petitioner sued in the Regional Trial Court, Iloilo City, Branch 25 (Civil Case No. 17045) for breach of contract and damages. The RTC dismissed the complaint for lack of sufficient cause of action and ordered petitioner to pay respondent P20,000 attorney’s fees plus P500 appearance fee and P50,000 exemplary damages. The Court of Appeals (CA) in CA‑G.R. CV No. 47227 affirmed the RTC’s decision and denied petitioner’s motion for reconsideration. Petitioner then filed a petition for review with the Supreme Court seeking reversal of the CA Decision dated February 4, 1999 and its Resolution dated September 7, 1999. The issues presented concerned (1) admissibility and probative value of the police blotter, (2) assessment of witness credibility, (3) propriety of exemplary damages and attorney’s fees, and the factual question of who was driving the insured truck at the time of the accident.
Issues:
- Was the police blotter admissible and entitled to prima facie evidentiary weight?
- Did the trial court and the Court of Appeals correctly assess the credibility of witnesses and factual findings?
- Were the awards of exemplary damages and attorney’s fees proper?
- On the facts, was Leonardo Anit the driver of the insured truck at the time of the accident?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)