G.R. No. 157658 - Philippine National Railways vs. Court of Appeals

On April 27, 1992, Jose Amores was traversing the railroad tracks along Kahilum II Street in Pandacan, Manila.
Prior to crossing, Amores momentarily stopped, then proceeded to cross when a Philippine National Railways (PNR) train (locomotive number T-517) suddenly appeared and collided with his vehicle.
At the time of the incident, there was no properly functioning warning system at the crossing. No signal, crossing bar, or flagman was present.
The only visible warning was a defective “Stop, Look and Listen” sign, which lacked the “Listen” component and had a bent “Look”.
Additionally, no whistle from the train was heard before the collision occurred, and after impact, the train dragged the car approximately ten (10) meters from the point of impact.
As a consequence of the accident, Jose Amores died.

Petitioners: Philippine National Railways (PNR) and its employee, Virgilio J. Borja (the locomotive driver on duty during the incident).
Respondents: The heirs of Jose Amores – comprising his surviving wife and six children – who initiated a Complaint for Damages.
The respondents alleged that the negligence of the petitioners, particularly the failure to install adequate safety devices (such as a crossing bar, semaphore, or flagman), was the proximate cause of the accident.
Conversely, the petitioners contended that Amores’ own carelessness and failure to observe proper traffic protocols in crossing the railroad tracks contributed to the accident.

On July 22, 1992, the respondents filed their complaint before the Regional Trial Court (RTC) of Manila, Branch 28, under Civil Case No. 92-61987, seeking actual and moral damages.
In August 1996, the RTC rendered a judgment in favor of the petitioners, dismissing the respondents’ complaint and attributing the proximate cause of the incident to Amores’ “fatal misjudgment” and carelessness.
The Court of Appeals (CA), however, reversed the RTC’s decision, holding that PNR and Borja were negligent in failing to provide sufficient warning measures at a level crossing located in a densely populated area.
The appellate court’s ruling imposed joint and several liability upon the petitioners for the damage to the vehicle and for moral damages, while denying claims that lacked sufficient documentary evidence.

The train was in proper operating condition with no defects (e.g., the speedometer was not defective as claimed).
Amores demonstrated negligence and carelessness by disregarding traffic precautions, despite having the “last clear chance” to avoid the accident.
The provisions of Section 42 of R.A. 4136 (Land Transportation and Traffic Code) mandated that motorists stop, look, and listen, implying that Amores should have been more cautious.

The failure of PNR to install basic safety measures (semaphore, crossing bar, flagman) at a crucial crossing in a dense, populated area was negligent.
The defective “Stop, Look and Listen” sign, non-operation of the train’s horn at the recommended distance, and the improper application of the train’s brakes contributed to the accident.

Evidence such as witness testimonies, transcript of stenographic notes, and expert observations underscored the inadequacy of the precautionary measures taken by PNR.

Whether the appellate court was correct in finding that the petitioners (PNR and its employee, Borja) were negligent in the operation of the train and in failing to secure proper warning devices at the railroad crossing.
Whether the negligence of the petitioners, evidenced by the absence of adequate safety measures (crossing bar, semaphore, flagman), constituted the proximate cause of the collision that led to Amores’ death.
Whether the respondents’ claims under the principles of quasi-delict, as provided in Article 2176 of the New Civil Code, were properly applied in establishing the petitioners’ liability.