Case Digest (G.R. No. 7380) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On December 25, 1993, at approximately 4:00 P.M., Werherlina P. Colipano and her infant daughter boarded a jeepney owned by Jose Sanico and driven by Vicente Castro en route to Natimao-an, Carmen, Cebu. Colipano paid her fare and was made to sit atop an empty beer crate at the rear exit with her sleeping child on her lap. As the vehicle ascended a hill, it lost power and slid backward. In an effort to prevent ejection, Colipano pressed her feet against the wet step board, slipped, and her left leg was crushed between the step board and a coconut tree, necessitating amputation. On January 7, 1997, she sued Sanico and Castro for breach of contract of carriage, seeking actual damages, loss of income, moral and exemplary damages, and attorney’s fees. The Regional Trial Court (RTC) found both defendants jointly liable and awarded ₱2,098.80 in actual damages and ₱360,000.00 in compensatory damages for loss of income. On appeal, the Court of Appeals (CA) affirmed the RTC’s ruling with Case Digest (G.R. No. 7380) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and parties
- On January 7, 1997, Werherlina P. Colipano (“Colipano”) filed a complaint for breach of contract of carriage and damages against Jose Sanico (“Sanico”), owner/operator of a jeepney, and Vicente Castro (“Castro”), its driver.
- The incident allegedly occurred on December 25, 1993 at around 4:00 P.M. in Carmen, Cebu, when Colipano and her young daughter were paying passengers in Sanico’s jeepney, driven by Castro.
- Circumstances of the accident
- Due to overcrowding, Colipano was made to sit on an empty beer case at the rear exit of the jeepney, with her sleeping child on her lap.
- The jeepney lost engine power on an uphill stretch to Natimao-an and slid backwards into a coconut tree. In trying to brace herself, Colipano’s left foot slipped on the wet step board and was crushed between the board and the tree, resulting in a severe leg injury and eventual amputation.
- Lower court proceedings
- The Regional Trial Court (Branch 25, Danao City) on October 27, 2006 found both Sanico and Castro liable for breach of contract of carriage; it awarded actual damages of ₱2,098.80 and compensatory damages for loss of income of ₱360,000.00.
- On September 30, 2013, the Court of Appeals affirmed with modification, reducing compensatory damages to ₱200,000.00 and maintaining joint and several liability of both respondents. No motion for reconsideration was filed.
- Supreme Court petition
- Sanico and Castro filed a Petition for Review on Certiorari under Rule 45, challenging (a) the finding of breach by both respondents; (b) the binding effect of an Affidavit of Desistance and Release of Claim executed by Colipano; and (c) the computation and amount of compensatory damages.
- Colipano opposed, asserting that only Sanico was party to the carriage contract, that the affidavit was void, and that her damages were correctly proven and computed.
Issues:
- Breach of contract of carriage
- Whether the Court of Appeals erred in holding both Sanico and Castro liable for breach of the contract of carriage.
- Whether Castro, as driver and employee, is a proper party to the carriage contract.
- Validity of the Affidavit of Desistance and Release of Claim
- Whether Colipano’s post-accident affidavit releasing her claim is binding.
- Whether the requisites for a valid waiver under the Civil Code were satisfied.
- Quantum of damages
- Whether the compensatory damages for loss of earning capacity were correctly computed and awarded.
- What the proper amount of compensatory damages should be, considering the applicable formula and evidence.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)