Case Digest (A.C. No. 7973, 10457)
Facts:
Mariano C. Mendoza and Elvira Lim, G.R. No. 160110, June 18, 2014, the Supreme Court Second Division, Perez, J., writing for the Court. This case arises from a vehicular collision on 7 March 1997 between an Isuzu Elf truck owned by respondent Leonora J. Gomez and driven by Antenojenes Perez, and a Mayamy Transportation bus registered in the name of petitioner Elvira Lim and driven by petitioner Mariano C. Mendoza; Mendoza was later charged in an information for reckless imprudence but evaded arrest, and respondents filed Civil Case No. 5352-V-97 for damages against Mendoza and Lim.Investigating officer PO1 Melchor Rosales reported that the Isuzu truck was in its proper lane and even stopped when the Mayamy bus, travelling in the opposite direction, intruded into the Isuzu's lane and struck it; Mendoza allegedly attempted to flee but was apprehended. The collision caused physical injuries to the Isuzu driver and helpers and damage to the Isuzu truck; respondents presented receipts for P142,757.40 (repairs) and P11,267.35 (medical expenses) and claimed unrealized income P1,000/day. Petitioners disputed ownership and presented testimony that Mayamy Transport was a sole proprietorship registered under another person, and thus contested vicarious liability.
The Regional Trial Court (RTC), Branch 172, Valenzuela City, found Mendoza directly negligent under Article 2176 and Lim vicariously liable under Article 2180 of the Civil Code, awarding repair costs, unrealized income, moral damages (P100,000), exemplary damages (P50,000), attorneys' fees (P50,000) and costs (Decision dated 31 January 2001). The Court of Appeals (Special Fourth Division) in CA‑G.R. CV No. 71877 (Decision dated 29 September 2003) affirmed the RTC but deleted the award for unrealized income while maintaining the other awards.
Petitioners filed this appeal by certiorari before the Supreme Court raising principally three objections: (a) that moral damages were improper because respondents' cause was quasi‑delict and they did not suffer physical injuries under Article 2219(2); (b) that exemplary damages were unwarranted absent gross n...(Pro-only)
Issues:
- Was Mendoza shown to be negligent and is Lim vicariously liable as registered owner?
- Were moral damages properly awarded to respondents?
- Were exemplary damages properly awarded against Mendoza and Lim?
- Was the award of attorneys...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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