Case Digest (G.R. No. 120553)
Facts:
Philtranco Service Enterprises, Inc. and Rogaciones Manilhig v. Court of Appeals and Heirs of the Late Ramon Acuesta, G.R. No. 120553, June 17, 1997, the Supreme Court Third Division, Davide, Jr., J., writing for the Court.The heirs of Ramon A. Acuesta (private respondents) sued petitioners Philtranco Service Enterprises, Inc. (employer) and its driver Rogaciones Manilhig in Civil Case No. 373 before Branch 31, Regional Trial Court (RTC), Calbayog City, for damages arising from a vehicular accident on 24 March 1990 that caused Acuesta’s death. The complaint alleged gross negligence, recklessness, violation of traffic rules, abandonment of the victim and attempted flight; the heirs were represented by Atty. Julio O. Acuesta, who was also one of the plaintiffs.
At trial the private respondents presented eight witnesses and, after cross-examination of the last witness on 10 February 1992, reserved the presentation of a ninth witness but later orally offered the evidence and rested. The hearings were set for 30–31 March 1992; petitioners’ counsel failed to appear on those dates and did not move for postponement. The RTC declared the case submitted on the basis of the plaintiffs’ evidence after denying motions for reconsideration, and later rendered a 22 January 1993 decision finding the driver negligent and Philtranco solidarily liable, awarding P55,615.72 actual damages; P200,000 death indemnity; P1,000,000 moral damages; P500,000 exemplary damages; P50,000 attorney’s fees; and costs.
Petitioners appealed to the Court of Appeals (CA-G.R. CV No. 41140). The Court of Appeals, in a 31 January 1995 decision, affirmed the RTC. The CA held the failure to present defense evidence amounted to waiver because petitioners and counsel were duly notified but did not appear and did not seek timely postponement; it also sustained findings of gross negligence and solidary liability under Articles 2176, 2180 and 2194 of the Civil Code and upheld awards of damages and attorney’s fees under applicable provisions.
Petitioners filed a petition for review under Rule 45 to the Supreme Court, principally arguing (1) denial of due process by being prevented from presenting evidence, (2) misapplica...(Pro-only)
Issues:
- Were the petitioners denied due process when the trial court declared the case submitted and thereby precluded them from presenting their evidence?
- Are petitioners solidarily liable under the Civil Code for damages caused by their driver, and may Philtranco invoke the defense of having exercised “all the diligence of a good father of a family”?
- Were the awards for death indemnity, moral damages, exemplary damages, and attorney’s fees supp...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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