Case Digest (G.R. No. 66102-04)
Facts:
Philippine Rabbit Bus Lines, Inc. v. The Honorable Intermediate Appellate Court and Casiano Pascua, et al., G.R. Nos. 66102-04, August 30, 1990, First Division, Medialdea, J., writing for the Court. Petitioner is Philippine Rabbit Bus Lines, Inc. (Rabbit); respondents include the Intermediate Appellate Court (now Court of Appeals) and private plaintiffs led by Casiano Pascua and other heirs/claimants.On December 24, 1966, several passengers — Catalina Pascua, Caridad Pascua, Adelaida (Florida) Estomo, Erlinda Meriales and others — boarded a jeepney owned by spouses Isidro Mangune and Guillerma Carreon and driven by Tranquilino Manalo for a trip to Rosales, Pangasinan. Passengers paid P24 for the trip. While traversing barrio Sinayoan, San Manuel, Tarlac, the jeepney’s right rear wheel detached; the driver braked and, according to plaintiffs’ witnesses, executed a sudden U-turn and stopped occupying most of the western lane. Bus No. 753 of Philippine Rabbit Bus Lines, Inc., driven by Tomas delos Reyes, collided with the rear-right portion of the jeepney. Three jeepney passengers died (Catalina Pascua, Erlinda Meriales, Adelaida Estomo) and others were injured.
Police sketches and photographs were introduced showing skid marks, the point of impact on the western lane about one yard from the center line, and a long skid track attributed to the jeepney. No skid marks attributable to the Rabbit bus were observed. Criminal proceedings followed: Manalo was convicted for Multiple Homicide and Multiple Serious Physical Injuries through Reckless Imprudence and served his sentence; the case against delos Reyes was dismissed at preliminary investigation.
Civil complaints for damages were filed in the Court of First Instance (now Regional Trial Court), Pangasinan: Civil Case No. 1136 (death of Catalina Pascua and injury to Caridad Pascua), No. 1139 (death of Erlinda Meriales), and No. 1140 (death of Adelaida Estomo). Defendants impleaded included Mangune and Carreon (owners), Manalo (jeepney driver), Philippine Rabbit Bus Lines, Inc. and Tomas delos Reyes (bus and driver), and Filriters Guaranty Assurance Corporation, Inc. (insurer of the jeepney in Case No. 1136). Plaintiffs sued the jeepney owners and driver on contractual liability; Rabbit and delos Reyes were sued on quasi-delict.
On December 27, 1978 the trial court found Manalo negligent, held spouses Mangune and Carreon and Manalo liable to plaintiffs (with Filriters jointly liable in Case No. 1136), and awarded damages; it also granted Rabbit’s cross-claim for damage to its bus against the jeepney defendants. The Intermediate Appellate Court on July 29, 1983 reversed in part, holding Rabbit and delos Reyes liable to the pl...(Pro-only)
Issues:
- May the Supreme Court reexamine the factual findings of the Intermediate Appellate Court when those findings are contrary to the trial court?
- Who is legally liable for the deaths and injuries of the jeepney passengers — the jeepney owners and driver, or the Rabbit bus and its driver?
- Should the indemnity for loss of life awarded be adjusted un...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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