Case Digest (G.R. No. L-26810)
Facts:
- A vehicular accident occurred on February 27, 1964, involving a Mercedes Benz driven by Alberto Concepcion and a bus operated by B.L.T. Bus Co., Inc., driven by Sergio de Luna.
- Plaintiffs Rosario Santos Vda. de Bonifacio, her family, and Agustin Angeles were passengers in the Mercedes Benz.
- The collision took place at approximately 5:20 a.m. in Barrio Landayan, San Pedro Tunasan, Laguna, on a slippery road due to drizzle.
- The Mercedes Benz was traveling at 30 miles per hour when the bus swerved into its lane, leading to the collision.
- Jovito Bonifacio, Sr. died, and the other passengers sustained serious injuries.
- The plaintiffs filed Civil Case No. 8275 in the Court of First Instance of Rizal (Pasig), which ruled in their favor, awarding P240,905.72 in damages plus interest.
- B.L.T. Bus Co., Inc. and Sergio de Luna appealed the decision.
Issue:
- (Unlock)
Ruling:
- The court determined that the proximate cause of the accident was the negligence of the B.L.T. bus driver, Sergio de Luna.
- The court held that B.L.T. Bus Co., Inc. was liable for the fault of its driver under Article 2180 of the Civil Code of the Phil...(Unlock)
Ratio:
Negligence of Sergio de Luna:
- De Luna failed to take necessary precautions under dark and rainy conditions.
- He drove at an unreasonable speed, causing the bus to skid and encroach into the lane of the Mercedes Benz.
- De Luna's failure to notice a parked cargo truck until he was only 50 meters away indicated his inattentiveness.
- The court found the defense's version of events incredible and unsupported by physical evidence.
Employer's Liability:
- Under Article 2180 of the Civil Code, an employer is liable for its employee’s damages unless due diligence in selection and supervision is proven.
- B.L.T. Bus Co., Inc. failed to demonstrate such diligence.
- The company showed laxity in supervising de Luna, who had a history of infractions, and in vehicle maintenance.
- Attempts to alter documents to hide these facts further weakened the company's defense.
Reasonableness of Damages:
- The court considered the deceased’s successful business career, medical expenses, and the mor...continue reading
Case Digest (G.R. No. L-26810)
Facts:
The case revolves around a vehicular accident that transpired on February 27, 1964, involving a Mercedes Benz driven by Alberto Concepcion and a passenger bus operated by B.L.T. Bus Co., Inc., driven by Sergio de Luna. The plaintiffs, Rosario Santos Vda. de Bonifacio and her family, along with Agustin Angeles, were passengers in the Mercedes Benz. The incident occurred at approximately 5:20 a.m. in Barrio Landayan, San Pedro Tunasan, Laguna, on a slippery concrete road due to drizzling rain. The Mercedes Benz was traveling at a speed of 30 miles per hour when it collided with the B.L.T. bus, which had swerved into its lane. The collision resulted in the death of Jovito Bonifacio, Sr., and caused serious injuries to the other passengers. Consequently, the plaintiffs filed a civil case (Civil Case No. 8275) in the Court of First Instance of Rizal (Pasig), which ruled in their favor, awarding them P240,905.72 in damages with interest from the filing of the complaint. The defendants, B.L.T. Bus Co., Inc., and Sergio de Luna, subsequently appealed the decision.
Issue:
- Who of the drivers of the colliding vehicles was at fault?
- Is the employer of the guilty driver responsible for the fault of the latter?
- Are the damages awarded reasonable?
Ruling:
- The court ruled that the proximate cause of the accident was the negligence of the B.L.T. bus driver, Sergio de L...