Title
Sanitary Steam Laundry, Inc. vs. Court of Appeals
Case
G.R. No. 119092
Decision Date
Dec 10, 1998
Collision between a panel truck and a Cimarron in 1980 caused fatalities and injuries. Supreme Court ruled the truck driver’s negligence as proximate cause, upheld damages, and held employer liable for inadequate driver supervision.

Case Digest (G.R. No. 119092)
Expanded Legal Reasoning Model

Facts:

  • Parties and Background
    • Petitioner: Sanitary Steam Laundry, Inc.
    • Respondents: The heirs and individual capacities of Jason Bernabe, John Joseph Bernabe, Victor Ignacio, Julieta Enriquez, Ramon Enriquez, Rene Tablante, Leomar Macaspac Jr., Charito Estolano, Nenita Salunoy, and others.
    • Incident: A collision involving petitioner’s Mercedes Benz panel truck and a Cimarron vehicle. The accident occurred on August 31, 1980, at Aguinaldo Highway, Imus, Cavite.
  • Details of the Accident and Victims
    • All victims were passengers of the Cimarron vehicle, including the driver, Rolando Hernandez, who died.
    • Three persons died: Driver Rolando Hernandez, Jason Bernabe, and Dalmacio Salunoy. Several others were injured.
    • The Cimarron was traveling back to Manila from Lian, Batangas, carrying mostly employees of Project Management Consultants, Inc. (PMCI) and their families/friends.
    • The panel truck was headed to petitioner’s plant in Dasmariñas, Cavite, after a delivery to Makati Medical Center.
  • Circumstances of the Collision
    • The panel truck driver, Herman Hernandez, claimed he braked suddenly due to a jeepney ahead stopping, causing his vehicle to swerve left and encroach partially into the opposite lane.
    • Petitioner’s vehicle collided with the Cimarron while on the Cimarron’s lane.
  • Legal Proceedings
    • A civil case was filed on December 4, 1980, by the respondents in Court of First Instance of Rizal, Pasig Branch, later transferred to RTC Makati.
    • On November 23, 1990, RTC Makati found petitioner liable for damages amounting to P472,262.30 and attorney’s fees of P50,000.00.
    • The Court of Appeals affirmed the decision in 1995.
    • Petitioner sought review with the Supreme Court contesting liability and damages awarded.

Issues:

  • Whether petitioner’s panel truck driver was negligent and liable for the accident.
  • Whether the driver of the Cimarron was contributorily negligent and whether such negligence mitigates or removes petitioner’s liability.
  • Whether petitioner exercised due diligence in the selection and supervision of its driver, and if it is liable as employer.
  • Whether the awards for actual, moral, death, and attorney’s fees damages were proper and supported by evidence.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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