Case Digest (G.R. No. 148974)
Facts:
The case involves OMC Carriers, Inc. and Jerry AAAalucas y Pitalino as petitioners against spouses Roberto C. Nabua and Rosario T. Nabua as respondents. The incident occurred on August 4, 1995, around 3:00 PM, when an Isuzu private tanker, owned by OMC Carriers and driven by its employee AAAalucas, collided with an Isuzu Gemini vehicle driven by 18-year-old Reggie T. Nabua. The accident took place on Quirino Highway in Barangay Pasong Putik, Novaliches, Quezon City, as the Gemini was making a left turn towards a Caltex gasoline station. The collision resulted in severe damage to the Gemini and the death of Reggie Nabua, who was pronounced dead upon arrival at Fairview Polymedic Hospital. Following the incident, the Nabua spouses filed a complaint for damages against the petitioners and the General Manager of OMC Carriers, Chito Calauag, in the Regional Trial Court (RTC) of Quezon City, which was docketed as Civil Case No. Q-95-24838. On January 19, 1998, the RTC ruled in favo...
Case Digest (G.R. No. 148974)
Facts:
- Incident Details: On August 4, 1995, an Isuzu private tanker owned by petitioner OMC Carriers, Inc. and driven by its employee, Jerry AAAalucas, collided with an Isuzu Gemini driven by Reggie Nabua, who was making a left turn towards a Caltex gasoline station. The collision resulted in Reggie Nabua's death.
- Legal Action: The parents of Reggie Nabua, respondents Berlino and Rosario Nabua, filed a complaint for damages against OMC Carriers, Inc., its General Manager Chito Calauag, and Jerry AAAalucas before the Regional Trial Court (RTC) of Quezon City.
- RTC Decision: The RTC ruled in favor of the respondents, awarding them various damages, including actual damages, compensatory damages, moral damages, exemplary damages, and attorney's fees.
- CA Decision: The Court of Appeals (CA) modified the RTC decision by absolving Chito Calauag from liability and deleting the awards for lost earnings and exemplary damages. The CA affirmed the rest of the RTC's decision.
- Petition to the Supreme Court: Petitioners OMC Carriers, Inc. and Jerry AAAalucas filed a petition for review on certiorari, challenging the CA's decision.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- Proximate Cause: The Court held that factual findings of the CA are binding unless there is grave abuse of discretion. The evidence, including eyewitness testimonies and skid marks, clearly pointed to AAAalucas's negligence as the proximate cause of the accident.
- Employer's Liability: Under Article 2180 of the Civil Code, an employer is liable for damages caused by its employees unless it can prove that it exercised the diligence of a good father of a family in the selection and supervision of the employee. OMC Carriers, Inc. failed to prove due diligence in supervision, as its evidence was largely oral and lacked documentary support.
- Damages:
- Death Indemnity: The Court followed established jurisprudence, which fixes death indemnity at P50,000.00.
- Moral Damages: Moral damages are meant to compensate for suffering, not to enrich the plaintiff. An award of P50,000.00 was deemed appropriate.
- Actual Damages: Only amounts supported by receipts can be awarded as actual damages. The Court reduced the award to P59,173.50, the amount substantiated by receipts.
- Attorney's Fees: The award of attorney's fees was deleted as there was no legal basis for it.
- Compensatory Damages: The Court upheld the CA's deletion of the P2,000,000.00 award for lost earnings, as there was no evidence that Reggie Nabua would have completed his education and secured employment.
Conclusion:
The Supreme Court partially granted the petition, affirming the CA's decision with modifications. The awards for death indemnity, moral damages, and actual damages were reduced, and the award for attorney's fees was deleted. The Court upheld the CA's deletion of the compensatory damages award. Petitioners were ordered to pay legal interest on the awarded amounts.