Case Digest (G.R. No. L-65295) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On the pre-dawn hours of November 15, 1975, private respondent Leonardo Dionisio was driving his Volkswagen home to Bangkal, Makati, after a cocktails-and-dinner meeting with his employer. Having consumed “a shot or two” of liquor, he crossed the General Santos–General Lacuna intersection when his headlights allegedly failed. Switching to “bright,” he discovered a Ford dump truck owned by Phoenix Construction, Inc. and driven by its regular operator, Armando U. Carbonel, parked askew on the right side of General Lacuna Street, protruding into the lane without lights or reflectors. Dionisio swerved left but collided with the truck, sustaining permanent facial scars, a nervous breakdown, and loss of two gold bridge dentures. He sued for damages in the Court of First Instance of Pampanga, attributing his injuries to the negligent parking of the truck by Carbonel. Phoenix and Carbonel countered that Dionisio’s own recklessness—speeding, driving under the influence, without headlight Case Digest (G.R. No. L-65295) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Accident Circumstances
- On 15 November 1975 at about 1:30 a.m., private respondent Leonardo Dionisio drove his Volkswagen home from a cocktails-and-dinner meeting, after taking “a shot or two” of liquor.
- As he crossed the intersection of General Lacuna and General Santos Streets in Bangkal, Makati, his headlights suddenly failed; upon switching them to “bright,” he saw a Ford dump truck owned by Phoenix Construction, Inc., parked askew on the right side, partly blocking the lane, without lights or reflector devices.
- Dionisio swerved to avoid it but collided with the truck, sustaining permanent facial scars, a nervous breakdown, and loss of two gold bridge dentures.
- Parties’ Contentions
- Dionisio alleged that the proximate cause of his injuries was the negligent parking of the dump truck by its driver, Armando U. Carbonel, with Phoenix vicariously liable.
- Phoenix and Carbonel countered that Dionisio was the true cause: he was speeding, driving without headlights, under the influence of liquor, and lacked a valid curfew pass; they also asserted they exercised due care in selecting and supervising Carbonel.
- Procedural History
- The Court of First Instance of Pampanga ruled for Dionisio, ordering Phoenix and Carbonel jointly and severally to pay:
- ₱15,000 for hospital bills and dentures replacement
- ₱150,000 as loss of expected income
- ₱100,000 as moral damages
- ₱10,000 as exemplary damages
- ₱4,500 as attorney’s fees
- Costs of suit
- The Intermediate Appellate Court (CA-G.R. No. 65476) affirmed but reduced:
- Compensatory damages to ₱6,460.71
- Loss of expected income to ₱100,000
- Moral damages to ₱50,000
- Left exemplary damages, attorney’s fees, and costs unchanged
- Petitioners elevated the case by certiorari to the Supreme Court, arguing Dionisio’s negligence was an intervening efficient cause and raising four factual issues: curfew pass, speed, headlight failure, and intoxication.
Issues:
- Proximate Cause and Intervening Negligence
- Whether Carbonel’s negligent parking was the legal and proximate cause of the collision and injuries.
- Whether Dionisio’s own negligence—speeding, driving without headlights, under the influence, and lacking a curfew pass—constituted an efficient intervening cause that negated or limited Phoenix and Carbonel’s liability.
- Specific Factual Questions
- Did Dionisio have a valid curfew pass that night?
- Was he driving at an unreasonable speed?
- Were his headlights accidentally malfunctioning or intentionally turned off?
- Was his alcohol consumption sufficient to establish reckless imprudence?
- Employer Liability
- Whether Phoenix, as employer, was solidarily liable for Carbonel’s negligence under respondeat superior and the doctrine of culpa in vigilando.
- Applicability of Common Law Doctrines
- Whether the “last clear chance” doctrine applies in Philippine civil law to mitigate contributory negligence.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)