G.R. No. 216569 - Philippine National Construction Corp. vs. Superlines Transportation Co., Inc.

A bus owned by Superlines Transportation Co., Inc. (Superlines) crashed into the radio room of Philippine National Construction Corporation (PNCC) while traveling north, damaging the structure.
After the crash, police authorities initiated an investigation. Due to space constraints, Patrolman Cesar Lopera instructed that the bus be towed and stored inside the PNCC compound.

Despite several requests by Superlines for the release of the bus, PNCC’s head of traffic control and security, Pedro Balubal, refused to release it.
Balubal demanded a sum of P40,000,000 or collateral equal to that amount, corresponding to the estimated cost of repairing the damaged radio room.

Superlines filed a complaint for replevin with damages against PNCC and Balubal before the Regional Trial Court (RTC) of Gumaca, Quezon, Branch 62.
In its answer, PNCC and Balubal claimed that they acted on orders from police authorities by towing the bus for safekeeping, and they counterclaimed for actual and exemplary damages, attorney’s fees, and litigation expenses.

The RTC dismissed Superlines’ complaint but ordered Superlines to pay PNCC actual damages amounting to P40,320.00 for the reconstruction of the radio room; PNCC counterclaimed successfully.
On appeal, the Court of Appeals (CA) held that because the bus was stored for safekeeping—a deposit-like arrangement—the custody remained with Patrolman Lopera, and PNCC was not at liberty to release the bus without his instruction, asserting that the case should have been brought against the police authorities.
In the earlier Supreme Court decision (G.R. No. 169596), the Court ruled in favor of Superlines by declaring the seizure unconstitutional, ordering the recovery of the bus, and stating that Lopera and other police officers should be impleaded as indispensable parties for any claim for damages.

Acting on the Supreme Court ruling, Superlines amended its complaint for damages to include Patrolman Lopera as an additional defendant.
Despite the amendment, the RTC later dropped Lopera from the list of defendants after due hearing, finding no liability on his part.
The RTC ruled that PNCC and Balubal were liable to pay damages for failing to deliver possession of the bus, awarding amounts covering the cost of replacing the bus, lost/unearned income over a lengthy period, exemplary damages, and attorney’s fees.
The CA, in its decision dated May 30, 2014, affirmed the trial court decision with modifications—specifically reducing the award for exemplary damages—while upholding the dismissal of unearned income claims.
PNCC subsequently filed a petition for review on certiorari challenging the dropping of Lopera as a party, among other issues.

Whether the exclusion (dropping) of Patrolman Lopera as an indispensable party in the claim for damages violates the Supreme Court’s previous ruling in G.R. No. 169596.

The issue centers on the obligation to implead indispensable parties when they have been identified by the Supreme Court as part of the chain of events constituting an illegal seizure.
Whether the trial court’s decision to drop Lopera, after a proper evidentiary hearing, conforms with the mandatory or directory nature of the Supreme Court order regarding impleading such parties.

Whether the modifications made by the CA regarding the award of damages, particularly the reduction of exemplary damages and attorney’s fees and the deletion of the claim for lost/unearned income, are justified based on the presented evidence.

The focus is on whether the data used for calculating lost/unearned income and exemplary damages was speculative and lacking sufficient basis.
Determination of the propriety of reducing the awarded sums to better reflect the actual and proven damages.