Title
Metro Manila Transit Corp. vs. Court of Appeals
Case
G.R. No. 116617
Decision Date
Nov 16, 1998
MMTC and its driver Musa are liable for Liza Rosalie's death due to negligence, with the court awarding damages to the Rosales spouses and holding GSIS responsible up to the policy limits.
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Case Digest (G.R. No. 116617)

Facts:

  • The case involves Metro Manila Transit Corporation (MMTC), its driver Pedro A. Musa, and spouses Rodolfo V. Rosales and Lily R. Rosales.
  • On August 9, 1986, MMTC Bus No. 27, driven by Musa, struck Liza Rosalie, the Rosales couple's daughter, while she was crossing Katipunan Avenue in Quezon City.
  • Liza was a third-year high school student at the University of the Philippines Integrated School.
  • Witnesses stated she was near the center of the street when the bus hit her, causing her to fall and be run over by the bus's rear tires.
  • Liza was pronounced dead upon arrival at the Philippine Heart Center.
  • Pedro Musa was found guilty of reckless imprudence resulting in homicide and sentenced to imprisonment by the Regional Trial Court of Quezon City.
  • The Rosales couple filed a civil action for damages against MMTC, Musa, and other MMTC officials, including Conrado Tolentino and Feliciana Celebrado.
  • The trial court ruled in favor of the Rosales couple, awarding them various damages and attorney's fees.
  • The Court of Appeals modified the trial court's decision, reducing actual damages but increasing death indemnity.
  • Both parties appealed the decision, leading to the current case.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court upheld the Court of Appeals' decision affirming the trial court's ruling that MMTC and Musa were liable for damages.
  • The Court modified the amounts awarded: death indemnity at P50,000, actual damages at P60,226.65, moral damages at P1,000,000, exemplary damages at P500,000, and attorney's fees at P50,000.
  • The Court rul...(Unlock)

Ratio:

  • The Supreme Court emphasized vicarious liability under Article 2180 of the Civil Code, holding employers liable for negligent acts of employees within the scope of their duties.
  • MMTC failed to prove it exercised due diligence in selecting and supervising Musa, lacking sufficient documentary evidence.
  • Testimonies were insuf...continue reading

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