Case Digest (G.R. No. 173180) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Albert Tison and Claudio L. Jabon v. Spouses Pomasin et al., decided on August 24, 2011 under the 1987 Philippine Constitution, a head-on collision occurred on August 12, 1994 along Maharlika Highway in Barangay Agos, Polangui, Albay, between a tractor-trailer owned by petitioner Albert Tison and driven by Claudio Jabon, and a jitney driven by Laarni Pomasin carrying her father Gregorio Pomasin and other relatives. Gregorio testified that the truck encroached their lane, causing the crash, while Jabon insisted the jitney zigzagged downhill after falling off the shoulder and struck his ascending vehicle. The accident killed five passengers and injured many others. Respondents filed a damage claim in the Regional Trial Court of Antipolo alleging negligence by petitioners and prayed for indemnity, medical and burial expenses, moral and exemplary damages, and attorney’s fees. Petitioners countered that Laarni’s imprudence was the proximate cause and invoked Cynthia Pomasin’s Affi Case Digest (G.R. No. 173180) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Accident
- On August 12, 1994, a tractor-trailer owned by Albert Tison and driven by Claudio Jabon collided with a jitney driven by Laarni Pomasin on Maharlika Highway in Barangay Agos, Polangui, Albay.
- Gregorio Pomasin, a passenger in the jitney, and other occupants suffered death or injuries; Jabon and one passenger in the tractor-trailer were injured.
- Versions of the Incident
- Passenger’s Version (Gregorio Pomasin): While descending a curve, the jitney was struck by the oncoming tractor-trailer, which encroached on its lane.
- Driver’s Version (Claudio Jabon): While ascending at 35–40 km/h, he saw the jitney veer off the shoulder and zigzag into his lane; he swerved right, struck a tree and sacks of palay, then was hit by the jitney.
- Procedural History
- Respondents sued petitioners for damages before the RTC of Antipolo on November 14, 1994, alleging negligence and claiming actual, medical, burial, moral, exemplary damages, attorney’s fees and litigation expenses.
- Petitioners countered that the jitney driver’s negligence caused the accident and invoked an Affidavit of Desistance executed by Cynthia Pomasin.
- On February 7, 2000, the RTC dismissed the complaint, finding Laarni Pomasin negligent and recognizing Cynthia’s tacitly consented settlement.
- The CA reversed on February 7, 2003, holding Jabon reckless, imposing liability on both Jabon and Tison, awarding actual, civil indemnity, moral damages and attorney’s fees; it disregarded the Affidavit of Desistance.
- The CA denied petitioners’ motion for reconsideration on July 19, 2006. Petitioners elevated the case to the Supreme Court via petition for review.
Issues:
- Whether the negligence of the tractor-trailer driver or the jitney driver was the proximate cause of the collision.
- Whether the Affidavit of Desistance executed by Cynthia Pomasin extinguished petitioners’ liability.
- Whether Albert Tison, as owner, exercised due diligence in supervising his driver.
- Whether the CA erred in presuming negligence per se from the license restriction violation without proving causal connection.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)