Case Digest (G.R. No. 201298) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On December 12, 1993, at approximately 8:45 AM, Loreta J. Yu alighted from a passenger bus in front of Robinsons Galleria along the northbound lane of EDSA when she was struck and run over by another bus driven by Antonio P. Gimena, an employee of R Transport Corporation (petitioner). Loreta was rushed to Medical City Hospital but was pronounced dead on arrival. On February 3, 1994, her husband, Luisito G. Yu (respondent), filed a Complaint for damages with the RTC of Makati City against R Transport, Antonio Gimena, and Metro Manila Transport Corporation (MMTC) for wrongful death. MMTC, as registered owner under the government’s Bus Installment Purchase Program, denied liability, asserting it merely purchased the bus for resale and did not operate it nor employ Gimena. R Transport denied negligence, claiming due diligence in selecting and supervising its drivers and proper maintenance of its buses. Gimena was declared in default for failing to answer. After trial, the RTC found Case Digest (G.R. No. 201298) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Accident and Death
- On December 12, 1993 at around 8:45 AM, Loreta J. Yu alighted from a passenger bus in front of Robinsons Galleria along the north-bound lane of EDSA.
- As she stood on the roadway, she was struck and run over by a bus driven by Antonio P. Gimena, an employee of petitioner R Transport Corporation.
- Medical and Immediate Aftermath
- Loreta was rushed to Medical City Hospital and was pronounced dead on arrival.
- An autopsy report indicated massive head injuries, with her brain exposed, consistent with a high-speed impact.
- Complaint and Defenses
- On February 3, 1994, respondent Luisito G. Yu filed a complaint for damages against R Transport, Antonio Gimena, and Metro Manila Transport Corporation (MMTC).
- MMTC denied liability as mere registered owner under a government installment purchase program, asserting R Transport was the actual owner and operator. R Transport pleaded due diligence in employee selection and supervision; Gimena failed to file an answer and was declared in default.
- Trial Court Decision
- After trial, the Regional Trial Court of Makati City found Gimena negligent and R Transport remiss in supervising him; MMTC was held solidarily liable to avoid unduly prejudicing the victim’s heirs.
- The RTC awarded actual damages (₱78,357), loss of income (₱500,000), moral damages (₱150,000), exemplary damages (₱20,000), attorney’s fees (₱10,000), and costs.
- Court of Appeals Proceedings
- On September 9, 2005, the CA affirmed the RTC decision with modification—making Gimena solidarily liable with R Transport and MMTC.
- On August 8, 2006, the CA denied R Transport’s motion for reconsideration.
- Supreme Court Petition
- R Transport filed a Rule 45 petition, arguing lack of evidence of driver negligence and reliance on speculation, and contending non-registered owners cannot be held liable.
- Respondent and the CA maintained that Gimena’s negligence was proven and Article 2180 of the Civil Code imposed solidary liability on employers and operators.
Issues:
- Whether the Court of Appeals erred in affirming the RTC’s finding of petitioner’s liability for the negligence of its employee despite alleged insufficient evidence.
- Whether a non-registered owner/operator like petitioner R Transport may be held solidarily liable under Article 2180 of the New Civil Code for damages caused by its employee.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)