Case Digest (G.R. No. 172122)
Facts:
Mercury Drug Corporation and Rolando J. Del Rosario v. Spouses Richard Huang and Carmen Huang, and Stephen Huang, G.R. No. 172122, June 22, 2007, First Division, Puno, C.J., writing for the Court.Petitioners are Mercury Drug Corporation (owner of a 1990 Mitsubishi six-wheeler truck) and its employee-driver Rolando J. del Rosario; respondents are spouses Richard and Carmen Huang and their son Stephen Huang, driver of a 1991 Toyota Corolla. On December 20, 1996 at about 10:30 p.m. on C-5 Highway in Taguig, the truck and the car collided. The truck, much heavier than the car, allegedly swerved left and struck the car; the car was hurled onto a center island, struck a lamppost, spun across lanes, and both vehicles ultimately stopped on the opposite side of the highway. Stephen sustained catastrophic injuries resulting in paralysis from the chest down and requires lifelong care.
At trial petitioners blamed Stephen for initiating contact; respondent contended Del Rosario negligently swerved into the car. Del Rosario testified he lost control and did not apply brakes; he was driving with only a Traffic Violation Receipt (TVR) because his license had been confiscated for prior reckless driving. An expert in physics, Dr. Marlon Daza, analyzed vehicle masses, speeds and trajectories and opined that the car’s post-impact movement was consistent with the truck being on the left and the car at its left (i.e., the truck swerving into the car), not the reverse.
The Regional Trial Court (RTC), Branch 64, Makati City, rendered a decision dated September 29, 2004 finding both Del Rosario and Mercury Drug jointly and severally liable and awarding actual damages (P2,973,000.00), life-care cost (P23,461,062.00), loss of earning capacity (P10,000,000.00), moral damages (P4,000,000.00), exemplary damages (P2,000,000.00), and attorney’s fees (P1,000,000.00). The Court of Appeals, in CA‑G.R. CV No. 83981, affirmed with modification on February 16, 2006, reducing mo...(Pro-only)
Issues:
- Did the Court of Appeals commit reversible error in denying petitioners’ motion for reconsideration and in affirming the RTC’s findings?
- Were petitioners Del Rosario and Mercury Drug liable for the injuries sustained by Stephen Huang — i.e., was Del Rosario negligent and was Mercury Drug vicariously (and directly) liable for failure to exercise due diligence in selection and supervision?
- Are the awards for actual damages, life-care cost, loss of earning capacity, moral and exemplary dam...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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