Facts:

• On May 4, 1993, at around 2:45 p.m., a collision occurred on Rafael Castillo St., Agdao, Davao City.
• The vehicles involved were a Datsun crewcab (plate number PEC-903) driven by Apolonio Deocampo and a 1958 Chevy pick-up (plate number MAM-475) owned by Michael Raymond Angala and driven by Bernulfo Borres.
• The crewcab, owned by Lapanday Agricultural and Development Corporation (LADECO) and assigned to its manager Manuel Mendez, was traveling north towards Lanang, Davao City.
• The crewcab struck the pick-up from behind, damaging the left door, front left fender, and part of the front bumper of the pick-up.
• Angala, seated beside the driver, filed an action for Quasi-Delict, Damages, and Attorney's Fees against LADECO, its administrative officer Henry Berenguel, and Deocampo.
• Angala claimed the pick-up was slowing down to make a left turn when it was hit by the crewcab traveling at 60 to 70 kph.
• Deocampo contended both vehicles were traveling at about 40 kph and that the pick-up made a sudden U-turn without signaling.
• The Regional Trial Court of Davao City found Deocampo negligent and held LADECO and Deocampo solidarily liable for damages.
• The Court of Appeals affirmed this decision, leading to the petition before the Supreme Court.

Issue:

• (Unlock)

Ruling:

1. The Supreme Court ruled that both drivers were negligent and that the doctrine of last clear chance applied, holding Deocampo responsible for the collision.
2. The Court affirmed the award of moral damages to the...(Unlock)

Ratio:

• The Supreme Court found both drivers negligent: Borres for not taking the proper lane before executing the U-turn, violating Section 45(b) of RA 4136, and Deocampo for driving too fast and failing to brake in time.
• The Court applied the doctrine of last clear chance, which holds that the party who had the last opportunity to avoid th...continue reading