Case Digest (G.R. No. 150157)
Facts:
In Mauricio Manliclic and Philippine Rabbit Bus Lines, Inc. v. Modesto Calaunan, G.R. No. 150157, decided January 25, 2007, petitioners driver Mauricio Manliclic and his employer Philippine Rabbit Bus Lines, Inc. (PRBLI) were sued by respondent Modesto Calaunan following a collision at approximately Kilometer 40 of the North Luzon Expressway in Barangay Lalangan, Plaridel, Bulacan on July 12, 1988. Calaunan’s owner-type jeep (PER-290), driven by Marcelo Mendoza, was struck in the rear by PRBLI Bus No. 353 (CVD-478) driven by Manliclic, causing the jeep to veer into a roadside ditch. Calaunan suffered minor injuries and the jeep was damaged. A criminal case (Crim. Case No. 684-M-89) for reckless imprudence was filed and heard first, during which Calaunan, Mendoza, and Fernando Ramos testified. On December 2, 1991 Calaunan filed Civil Case No. D-10086 in the RTC of Dagupan City, alleging negligence and claiming damages. Both parties admitted key facts—vehicles, drivers, date, placCase Digest (G.R. No. 150157)
Facts:
- Parties and Vehicles
- Petitioners: Mauricio Manliclic (driver) and Philippine Rabbit Bus Lines, Inc. (owner of Bus No. 353, plate CVD-478).
- Respondent: Modesto Calaunan (owner of owner-type jeep, plate PER-290) driven by Marcelo Mendoza.
- Collision and Consequences
- On July 12, 1988 (6–7 AM) at km 40, North Luzon Expressway, both vehicles bound for Manila collided: bus’s front right struck jeep’s rear left, forcing the jeep into a roadside ditch; bus veered left and stopped 7–8 m from impact.
- Calaunan suffered minor injuries; driver Mendoza unhurt. Jeep was extensively damaged, requiring towing and repair; Calaunan hospitalized.
- Procedural History
- Criminal Case No. 684-M-89 (RTC Malolos): Manliclic charged with reckless imprudence resulting in damage to property with physical injuries; tried first.
- Civil Case No. D-10086 (RTC Dagupan): Filed December 2, 1991 by Calaunan against Manliclic and PRBLI for quasi-delict damages; numerous stenographic transcripts (TSNs) from the criminal case were offered and admitted.
- RTC Dagupan rendered judgment (July 22, 1996) holding petitioners solidarily liable for ₱40,838 actual damages, ₱100,000 moral, ₱100,000 exemplary, and ₱15,000 attorney’s fees.
- Court of Appeals (September 28, 2001) affirmed the RTC decision. Petitioners elevated the case to the Supreme Court via petition for review.
Issues:
- Whether the TSNs and documents from the criminal case were admissible in the civil suit.
- Which party’s version of how the collision occurred is credible for negligence attribution.
- Whether PRBLI exercised due diligence in selecting and supervising its employee (Manliclic) to avert vicarious liability.
- Whether the awards for actual, moral, exemplary damages, and attorney’s fees were proper in amount and legal basis.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)