Case Digest (G.R. No. 141525)
Facts:
In Philtranco Service Enterprises, Inc. v. Felix Paras and Inland Trailways, Inc., G.R. No. 161909, decided on April 25, 2012 under the 1987 Constitution, respondent Felix Paras (Paras) boarded an Inland Trailways, Inc. bus on February 8, 1987 en route from the Bicol Region to Manila. At about 3:50 a.m. on February 9, 1987, along Maharlika Highway in Tiaong, Quezon, the Inland bus was violently struck in the rear by a Philtranco bus driven by Apolinar Miralles. The collision forced the Inland bus into a parked cargo truck, causing serious injuries to Paras—diagnosed at the National Orthopedic Hospital with contusion, hematoma, dislocated hip, fibula fracture, small bone fracture in the right leg, and tibial plateau fracture of the left leg—and extensive damage to Inland’s vehicle. Paras underwent two surgeries on March 4 and April 15, 1987. On July 31, 1989, he sued Inland for breach of contract of carriage, alleging negligence. Inland denied liability and, on March 2, 1990, filCase Digest (G.R. No. 141525)
Facts:
- Parties and Background
- Petitioner: Philtranco Service Enterprises, Inc. (“Philtranco”) and its driver Apolinar Miralles.
- Respondents:
- Felix Paras (“Paras”), passenger and plaintiff in the breach-of-contract suit against Inland.
- Inland Trailways, Inc. (“Inland”), common carrier and third-party plaintiff.
- Accident and Initial Suit
- On 08–09 February 1987, Paras boarded an Inland bus traveling to Manila. At Tiaong, Quezon, Philtranco’s bus rear-ended the Inland bus, which then struck a parked truck.
- Consequences: serious injuries to Paras, death of Inland’s driver Calvin Coner, and material damage to Inland’s bus.
- Paras underwent two surgeries and extensive hospitalization. Lacking funds, he sued Inland on 31 July 1989 for breach of contract of carriage.
- Third-Party Complaint and Lower Court Judgment
- On 02 March 1990, Inland impleaded Philtranco and Miralles via third-party complaint seeking indemnity/subrogation under quasi-delict.
- RTC (Branch 71, Antipolo) on 18 July 1997 held Philtranco and Miralles jointly liable, awarding Paras actual damages, moral damages, attorney’s fees and costs.
- Court of Appeals Decision
- CA promulgated on 25 September 2002, affirming with modifications:
- To Paras: P1,397.95 actual; P50,000 temperate; P50,000 moral; P20,000 attorney’s fees.
- To Inland: P250,000 temperate damages.
- Philtranco’s motion for reconsideration was denied on 23 January 2004.
- Supreme Court Appeal
- Philtranco challenged the CA’s grant of moral damages (breach-of-contract suit) and motu proprio temperate damages.
- Paras and Inland did not separately appeal the temperate damages awards.
Issues:
- Whether Paras can recover moral damages in a breach of contract of carriage suit when impleaded third-party defendant’s liability is based on quasi-delict.
- Whether the CA erred in awarding temperate damages motu proprio, despite no plea for such relief by Paras or Inland.
- Whether Paras’s lost earnings (unearned income) during disability should be compensated.
- Whether attorney’s fees and legal interest awards are proper and in what amounts.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)