Case Digest (G.R. No. 141856)
Facts:
This is Philippine Rabbit Bus Lines, Inc. v. Sinforoso F. Macalinao (substituted by his widow Clarita Macalinao) and Valentin Macalinao, G.R. No. 141856, February 11, 2005, Supreme Court Third Division, Sandoval-Gutierrez, J., writing for the Court.On the evening of August 18, 1990, respondents Sinforoso and Valentin Macalinao were returning from work on two tractors along MacArthur Highway, Urdaneta, Pangasinan. Valentin’s tractor was struck from the rear by a car and became immobilized, occupying both lanes; Sinforoso used his tractor’s light to warn traffic and placed a lighted can some 15 meters away in each direction as an improvised early warning device. Police (SPO1 Asterio Dismaya and Sgt. Alfredo Islaba) investigated the scene and instructed them to keep the lights on.
At about 9:30 p.m., during heavy rain, a passenger bus of petitioner Philippine Rabbit Bus Lines, Inc., driven by Julius Castelo, approached on MacArthur Highway. Castelo saw the car on the shoulder about 15 meters away and veered left; he did not see the tractor until about 5 meters away and then collided with its left front side, causing the bus to veer into a ricefield. Petitioner's driver was later alleged to have been traveling at excessive speed.
On January 14, 1991, Sinforoso demanded P74,010 for tractor damages and P1,300 per day for lost income. Instead of complying, petitioner filed a complaint for damages against respondents on March 7, 1991 (Records, Civil Case No. 7401, RTC Branch 65, Tarlac). On April 7, 1995, the Regional Trial Court rendered judgment in favor of defendants (respondents), dismissing the complaint and ordering the plaintiff to pay P72,000 as actual damages and P10,000 as attorneys’ fees. Petitioner’s motion for reconsideration was denied.
The Court of Appeals (CA-G.R. CV No. 52177), in a decision penned by Associate Justice Eugenio S. Labitoria, affirmed the trial court, holding that factual findings supported by evidence — including functioning lights, the improvised warning device, the straightness of the road, and indications of bus overspeeding — showed respondents were not negligent and that the bus driver had the last clear chance to avoid the collision. The CA also found the damage awards reasonable. The CA denied petitioner’s motion for reconsideration in a February 1, 2000 Resolution.
Petitioner then brought this Rule 45 petition for review on certiorari to the Supreme Court, raising two assignments of error: (1) that respondents’ negligence was the direct and proxi...(Pro-only)
Issues:
- May the Supreme Court re-evaluate and disturb the trial court’s factual findings affirmed by the Court of Appeals in this Rule 45 petition (i.e., do any exceptions to the rule limiting review to questions of law apply)?
- Were respondents’ alleged negligent acts the direct and proximate cause of the collision?
- Did the Court of Appeals err in denying the ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)