Case Digest (G.R. No. 125817) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 125817 decided on January 16, 2002 under the 1987 Constitution, private respondent Donato H. Gonzales purchased in 1982 an Isuzu passenger jeepney from Gomercino Vallarta, the registered holder of a certificate of public convenience (CPC) for the Monumento-Bulacan route. Although Gonzales operated the vehicle continuously for public transport services, he neither had the certificate transferred nor secured a new CPC in his name, thus leaving Vallarta as the owner and operator of record. On July 22, 1990, while traveling northbound on the North Diversion Road in Meycauayan, Bulacan, the jeepney was struck by a ten-wheeler truck owned by petitioner Abelardo Lim and driven by Esmadito Gunnaban, whose negligence in handling a brake-failed vehicle caused the collision. The impact damaged the jeepney and a nearby Ferroza automobile, killed one passenger, and injured several others. Although Lim offered to repair the jeepney or pay P20,000 (later raised to P40,000), Gonzale Case Digest (G.R. No. 125817) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Acquisition and Registration
- In 1982, private respondent Donato Gonzales purchased an Isuzu passenger jeepney from Gomercino Vallarta, the registered owner under a Certificate of Public Convenience (CPC) for the Monumento-Bulacan route.
- Under the “kabit” system, Gonzales operated the jeepney without transferring registration or securing his own CPC; Vallarta remained the registered owner and operator.
- Collision and Aftermath
- On 22 July 1990, the jeepney was struck northbound on North Diversion Road by a ten-wheeler truck owned by petitioner Abelardo Lim and driven by Esmadito Gunnaban, whose brakes had failed. The crash also involved a Ferroza vehicle, resulting in one fatality and multiple injuries.
- Lim compensated hospital expenses, restored the Ferroza, and offered to repair Gonzales’s jeepney for P20,000–P40,000, which Gonzales rejected, instead demanding P236,000 or a new jeepney.
- Procedural History
- Trial court (RTC, Malolos) held Gunnaban negligent and Lim vicariously liable for lack of due diligence; awarded Gonzales P236,000 compensatory damages (with legal interest from date of accident) and P30,000 attorney’s fees.
- Court of Appeals affirmed, acknowledging the kabit system but invoking equity to allow Gonzales to sue as real party in interest.
- Petitioners elevated the case to the Supreme Court.
Issues:
- Whether a non-registered owner/operator under the kabit system may sue for damages without joining the registered owner.
- Whether the award of P236,000 plus legal interest from the date of the accident and P30,000 attorney’s fees is proper.
- Proper date from which legal interest on unliquidated damages should accrue.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)