Case Digest (G.R. No. L-47772)
Facts:
Inocencio Tugade v. Court of Appeals and People of the Philippines, G.R. No. L-47772, August 31, 1978, Supreme Court Second Division, Fernando, J., writing for the Court.At about 9:15 a.m. on January 4, 1972, Rodolfo Rayandayan was driving a Holden Kingswood car owned by the Sta. Ines Mining Corp. along Ayala Avenue, Makati, when he stopped to await a left-turn signal. While stopped, his car was struck from behind by a Blue Car taxi driven by petitioner Inocencio Tugade, causing damage to the Holden estimated at P778.10. Tugade admitted that the collision was caused by malfunctioning brakes on his taxicab and executed a handwritten statement to that effect.
Tugade was charged with Reckless Imprudence Resulting in Damage to Property. The trial court found him guilty beyond reasonable doubt, sentenced him to pay a fine of P1,000 (with subsidiary imprisonment in case of insolvency under Article 39 of the Revised Penal Code), ordered indemnity to Sta. Ines Mining Corp. in the amount of P778.10, and imposed costs. On appeal, Tugade reiterated that the malfunctioning brakes were a mechanical defect which could not have been prevented even with the exercise of due diligence and therefore amounted to a circumstance beyond his control.
The Court of Appeals, with Justice Juliano Agrava as ponente, reviewed the record and affirmed the trial court’s judgment in toto in a decision dated December 15, 1977. Petitioner then filed a petition for review with the Supreme Court seeking reversal of the Court of Appeals’ decision, principally arguing that the Supreme Court precedent relied upon by the Court of Appeals (notably La Mallorca a...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in applying this Court’s decision in La Mallorca (Pampanga Bus Co. v. De Jesus) because that decision was merely obiter dictum?
- Does a mechanical defect such as faulty brakes constitute a caso fortuito (fortuitous event) that absolves a driver from criminal liability for reckless imprudence result...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)