Case Digest (G.R. No. 140746)
Facts:
In the afternoon of October 28, 1984, Crispin Gicale was driving a passenger jeepney owned by his mother, Martina Gicale, along the National Highway in Talavera, Nueva Ecija, when a heavy rain reduced visibility. While negotiating a curve, a passenger bus owned by Pantranco North Express, Inc. and driven by Alexander Buncan overtook the jeepney, struck its left rear side, and sped away. Crispin immediately reported the accident to the Talavera Police Station and to Standard Insurance Company, Inc., the jeepney’s insurer. The total repair cost amounted to ₱21,415.00, of which Standard paid only ₱8,000.00, leaving Martina Gicale to pay the remaining ₱13,415.00. Standard Insurance and Martina Gicale then demanded reimbursement from Pantranco and Buncan, who refused. Consequently, Standard Insurance and Martina Gicale filed a complaint for sum of money before the Regional Trial Court (RTC), Branch 94, Manila, seeking recovery of the ₱8,000.00 and ₱13,415.00, plus interest, attorney’Case Digest (G.R. No. 140746)
Facts:
- Parties and Insurance
- Petitioners: Pantranco North Express, Inc. (owner of passenger bus) and its driver Alexander Buncan.
- Respondents: Martina Gicale (owner of jeepney), Crispin Gicale (jeepney driver), and Standard Insurance Company, Inc. (insurer of the jeepney).
- Accident and Damages
- On October 28, 1984, while driving northbound in Talavera, Nueva Ecija, in rainy conditions, petitioners’ bus overtook and collided with respondent Gicale’s jeepney.
- Total repair cost amounted to ₱21,415.00; Standard Insurance paid ₱8,000.00 and Martina Gicale paid the remaining ₱13,415.00 out of pocket.
- Judicial Proceedings
- Respondents demanded reimbursement; petitioners refused, prompting respondents to file a complaint for sum of money with the RTC, Branch 94, Manila.
- June 5, 1992 RTC Decision awarded ₱8,000.00 to Standard Insurance, ₱13,415.00 to Martina Gicale, plus interest, attorney’s fees of ₱10,000.00, litigation expenses, and costs.
- July 23, 1999 Court of Appeals (CA) Decision affirmed the RTC, applying the “totality rule” to aggregate the two claims (₱21,415.00) and confirming RTC jurisdiction; November 4, 1999 CA Resolution denied petitioners’ motion for reconsideration.
- Petitioners filed a petition for review on certiorari before the Supreme Court.
Issues:
- Whether the RTC had jurisdiction over the action, given that each respondent’s cause of action arose from separate claims and allegedly lacked common questions of law or fact.
- Whether petitioners are liable to respondents under the evidence and applicable law.
- Whether petitioners were deprived of due process when the case was deemed submitted for decision without their presentation of evidence.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)