Case Digest (G.R. No. 160286)
Facts:
Spouses Francisco M. Hernandez and Aniceta Abel‑Hernandez and Juan Gonzales, Petitioners v. Spouses Lorenzo Dolor and Margarita Dolor, Fred Panopio, Joseph Sandoval, Rene Castillo, Spouses Francisco Valmocina and Virginia Valmocina, Spouses Victor Panopio and Martina Panopio, and Hon. Court of Appeals, Respondents, G.R. No. 160286, July 30, 2004, First Division, Ynares‑Santiago, J., writing for the Court.
On December 19, 1986, at about 3:00 p.m., an owner‑type jeepney (plate DEB 804) driven by Lorenzo Menard Boyet Dolor, Jr. (and owned by his mother, Margarita Dolor) collided with a passenger jeepney (plate DEG 648) driven by petitioner Juan Gonzales and owned by petitioners Spouses Francisco M. Hernandez and Aniceta Abel‑Hernandez while traversing a road in Barangay Anilao East, Mabini, Batangas. Boyet Dolor and his passenger Oscar Valmocina died. Several passengers and occupants of both vehicles sustained injuries and property damage to the vehicles.
Private respondents sued before the Regional Trial Court (Branch IV, Batangas City; Civil Case No. 2790), alleging negligence by driver Gonzales and negligent selection/supervision by the Hernandez spouses. Petitioners countered that the proximate cause was the recklessness and intoxication of Boyet Dolor; they also maintained Gonzales was a daily lessee (not an employee) of the Hernandez spouses and that, if an employment relationship existed, they exercised due care in selection and supervision.
At trial the court found the road to be in fairly good condition, drivers duly licensed (Gonzales had obtained a professional license only three months earlier), the owner‑type jeepney was moving moderately and had just passed a bend when the passenger jeepney—allegedly traveling fast—struck it. On November 24, 1997, the trial court ruled for the plaintiffs and awarded various damages (including P50,000 for death to the Dolor spouses; funeral and other amounts to other respondents; moral damages; and attorneys’ fees), directing petitioners to pay jointly and severally.
Petitioners appealed to the Court of Appeals (CA‑G.R. CV No. 60357). On April 29, 2003 the Court of Appeals affirmed the trial court's liability findings but modified the awards: it adjusted funeral and other actual expenses, replaced some items with temperate damages, increased moral damages for certain respondents, and retained awards of litigation expenses and attorneys’ fees in specified amounts. Petitioners then filed a petition for review under Rule 45 to the Supreme Court raising, in substance: (1) whether the Hernandez spouses could be held solidarily liable with Gonzales desp...(Subscriber-Only)
Issues:
- Were the Hernandez spouses properly held solidarily liable with Juan Gonzales for the damages caused by the collision?
- Did the Court of Appeals err in awarding temperate damages to respondents though the trial court did not?
- Was the Court of Appeals correct in increasing the awards of moral damages to certain respondents?
- Was the grant of attorneys’ fees by the Court of Appeals justified where the trial court did n...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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