Case Digest (G.R. No. L-65295)
Facts:
Phoenix Construction, Inc. and Armando U. Carbonel v. The Intermediate Appellate Court and Leonardo Dionisio, G.R. No. 65295, March 10, 1987, the Supreme Court First Division, Feliciano, J., writing for the Court (Yap, Narvasa, Cruz, Gancayco, and Sarmiento, JJ., concur; Melencio‑Herrera, J., took no part).Private respondent Leonardo Dionisio (plaintiff in the trial court) was driving home shortly after cocktails on 15 November 1975 when his Volkswagen allegedly suffered a sudden headlight failure and he collided with a parked Ford dump truck owned and registered to petitioner Phoenix Construction, Inc. The dump truck had been driven home and parked that night by its regular driver, petitioner Armando U. Carbonel, with his employer’s permission; it was parked askew on the right side of General Lacuna Street, protruding into the lane, with no lights or warning reflectors. Dionisio sustained physical injuries, scars, a nervous breakdown, and loss of dental bridges. Dionisio alleged the truck’s negligent parking caused the collision; petitioners countered that Dionisio drove recklessly, under the influence, without headlights and without a curfew pass, and that Phoenix had exercised due care in selecting and supervising Carbonel.
Dionisio sued for damages in the Court of First Instance of Pampanga. The trial court found for Dionisio and awarded P15,000 (hospital bills and dentures), P150,000 (loss of expected income), P100,000 (moral damages), P10,000 (exemplary damages), P4,500 (attorney’s fees), and costs. Petitioners appealed to the Intermediate Appellate Court (CA-G.R. No. 65476), which affirmed liability but reduced the awards: compensatory damages lowered to P6,460.71, loss of expected income reduced to P100,000, and moral damages reduced to P50,000; exemplary damages, attorney’s fees and costs were left unchanged.
Petitioners filed a petition for review with the Supreme Court. The Court noted that both lower courts found Carbonel negligent in parking the truck, but neither expressly evaluated whether Dionisio’s own negligence (speeding, extinguishing headlights, lack of curfew pass, possible intoxication) constituted an intervening efficient cause that would bar or reduce recovery. The Court examined four factual questions — possession of a curfew pass, speed, whether headlights were purposely turned off o...(Subscriber-Only)
Issues:
- Was the petitioners’ claim that Dionisio’s negligence was an intervening, efficient cause that made him solely liable and absolved petitioners from responsibility correct?
- Are petitioners (driver Carbonel and employer Phoenix) liable for the collision and subject to respondeat superior / culpa in vigilando?
- Should the damages awarded by the Intermediate Appellate Court be modified ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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