Case Digest (G.R. No. 224186) Core Legal Reasoning Model
Facts:
The case involves spouses Emilio Mangaron, Jr. and Erlinda Mangaron (petitioners) who filed a complaint for damages under Articles 2180 and 2184 of the Civil Code against Hanna Via Design & Construction - Deepwell Drilling Division (respondent), Power Supply and Equipment Parts (Power Supply), and their company driver, Crestino T. Bosquit (Bosquit). The complaint arose from an accident where Bosquit, driving an Isuzu Truck with plate number PLM 612, hit and dragged the petitioners' vehicle, a Ford Ranger Pick-Up (plate number XJZ-830), causing serious physical injuries to the petitioners who were hospitalized for a month at Davao Doctors Hospital in Davao City. Petitioners invoked the vicarious liability of the respondent for Bosquit’s negligence. During trial, after petitioners rested their case, respondent filed a motion for demurrer to evidence, contesting the trial court’s jurisdiction on the ground that the complaint is essentially a criminal action for reckless im
Case Digest (G.R. No. 224186) Expanded Legal Reasoning Model
Facts:
- Parties and Complaint
- Spouses Emilio Mangaron, Jr. and Erlinda Mangaron (petitioners) filed a complaint for damages against Hanna Via Design and Construction - Deepwell Drilling Division (respondent), Power Supply and Equipment Parts (Power Supply), and their company driver, Crestino T. Bosquit (Bosquit).
- The complaint was filed under Article 2184 of the Civil Code in relation to Article 2180, alleging vicarious liability of the respondent due to the negligent driving of Bosquit.
- The incident involved an Isuzu truck with Plate Number PLM 612 (subject vehicle) owned by Power Supply that bumped and dragged petitioners' Ford Ranger Pick-Up with Plate Number XJZ-830, causing serious physical injuries.
- Petitioners were hospitalized for a full month at Davao Doctors Hospital due to the injuries sustained.
- Trial Court Proceedings
- After petitioners rested their case, the respondent filed a Motion for Demurrer to Evidence.
- Respondent challenged the RTC’s jurisdiction, asserting the complaint was criminal in nature (reckless imprudence resulting in physical injuries) and should have been filed in Davao City where the incident occurred.
- The RTC of Malolos City, Branch 11, denied the motion on May 20, 2014, ruling that issues raised were matters of evidence and that the case was civil in nature.
- Respondent’s Motion for Reconsideration was denied on September 26, 2014.
- Court of Appeals Proceedings
- Respondent filed a Petition for Certiorari with the CA to challenge the RTC’s jurisdiction denial.
- On October 20, 2015, the CA upheld the RTC’s jurisdiction but reversed the denial of the demurrer to evidence, finding grave abuse of discretion by the RTC.
- The CA held that Power Supply, as the registered owner of the subject vehicle, was primarily liable, not Hanna Via Design and Construction.
- Petitioners filed a Motion for Reconsideration, which the CA denied on April 14, 2016.
- Petition to the Supreme Court
- Petitioners assailed the CA ruling for:
- Giving due course to the certiorari petition despite the denial of motion for demurrer being interlocutory;
- Setting aside the RTC’s order despite alleged sufficient basis for its denial.
Issues:
- Whether the denial of the motion for demurrer to evidence by the RTC was proper.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)