G.R. No. L-22272 - Mara vs. Perez

On October 18, 1960, Rogelio Corachea was a passenger in a taxicab owned and operated by Pascual Perez.
Rogelio was stabbed and killed by the cab driver, Simeon Valenzuela.
Valenzuela was prosecuted for homicide before the Court of First Instance of Batangas.
He was found guilty and sentenced to imprisonment and ordered to indemnify the heirs of Rogelio in the amount of ₱6,000.
Valenzuela appealed to the Court of Appeals.

On December 6, 1961, while the appeal was pending, Antonia Maranan (Rogelio’s mother) filed a separate civil action in the Court of First Instance of Batangas
She sought damages from Pascual Perez and Simeon Valenzuela for the death of her son.
Defendants asserted self-defense, claiming the deceased stabbed the driver first from behind.
Defendant Perez further claimed the death was a caso fortuito (fortuitous event), thus exempting the carrier from liability.
After trial, the court ruled in favor of Antonia Maranan, awarding ₱3,000 damages against defendant Pascual Perez.
The claim against driver Valenzuela was dismissed.

Both plaintiff and defendant Perez appealed to the Supreme Court: plaintiff sought higher damages, while Perez contested liability.
During the pendency of the appeal, the Court of Appeals affirmed Valenzuela’s criminal conviction on May 19, 1964.

Whether Pascual Perez, as common carrier and owner of the taxicab, is liable for the death of his passenger committed by the driver, Simeon Valenzuela.
Whether the killing was a fortuitous event exempting the carrier from liability.
Whether the driver’s act occurred within the scope of his employment.
Whether the awarded damages were proper and should be increased.
Whether the plaintiff can hold the driver civilly liable in the civil action apart from the criminal case.