G.R. No. L-25499 - Villa Rey Transit, Inc. vs. Court of Appeals

This case arises from a wrongful death incident involving a passenger bus operated by Villa Rey Transit, Inc.
The petitioner, Villa Rey Transit, Inc., seeks review by certiorari of a decision of the Court of Appeals which affirmed the decision rendered by the Court of First Instance of Pangasinan.

On the early morning of March 17, 1960, at about 1:30 a.m., an Izuzu First Class passenger bus owned by Villa Rey Transit, Inc. left Lingayen, Pangasinan for Manila.
Among the passengers was Policronio Quintos, Jr. who occupied the first seat in the second row on the right side of the bus.
At approximately 4:55 a.m., as the bus neared the northern approach of the Sadsaran Bridge along the national highway in barrio Sto. Domingo, Minalin, Pampanga, the bus collided with the rear side of a bullcart loaded with hay.
A bamboo pole, about 8 feet long, attached to the bullcart was dislodged during the impact, striking the windshield and ultimately hitting Policronio Quintos, Jr., causing him to fall and sustain severe injuries including:

Emergency assistance was rendered by a Patrolman and a La Mallorca passenger bus, which transported the injured to the provincial hospital of San Fernando, Pampanga.
Despite the medical attention, Policronio Quintos, Jr. died at 3:15 p.m. on the same day as a result of traumatic shock from cerebral injuries.

Private respondents – Trinidad, Prima, and Julita Quintos – are the sisters and only surviving heirs of the deceased, Policronio Quintos, Jr.
The respondents instituted the suit against Villa Rey Transit, Inc. for breach of the contract of carriage, seeking damages amounting to P63,750.00 which, as detailed in the trial proceedings, comprised not only monetary losses but also included attorney’s fees.

The trial court and the Court of Appeals found that the accident resulted solely from the negligence of the bus driver, for which the petitioner was held liable under the contract of carriage.
Damages were computed based on two primary factors:

The life expectancy of Policronio Quintos, Jr. estimated at 33⅓ years, derived from actuarial tables (American Expectancy Table of Mortality or Combined Experience Table of Mortality).
The rate of damages based on the victim’s net earning capacity at the time of his death, which was established to be P2,184.00 per year, reflecting his salary as a “training assistant” at Bacnotan Cement Industries, Inc.

It was clarified that damages are not computed on the gross earnings but rather on the net earnings, deducting necessary personal living and incidental expenses.
Additional awards included sums for statutory penalties under relevant provisions of the Revised Penal Code, actual expenses incurred for medical and burial costs, and attorney’s fees.

The petitioner contended that the accident was due to a fortuitous event, denying negligence on the part of its driver.
The petitioner also challenged both the adoption of the life expectancy formula (as opposed to a fixed four-year basis argued in Alcantara v. Surro) and the rate at which the damages were computed.
Specifically, the petitioner objected to differences in the computation of future income, pointing out a contrast with the Alcantara case, although that case was held not to be controlling in the present matter.

Deductible living and necessary expenses, fixed at P1,184.00 per year.
The additional damages for punitive provisions, medical and burial expenses, and increased attorney’s fees.

The final award was reduced to an aggregate sum of P49,561.28 with interest from December 29, 1961.

Whether the lower courts erred in basing the computation of the damages on the life expectancy of Policronio Quintos, Jr. as opposed to a fixed period (such as the four-year rule cited in Alcantara v. Surro).

The appropriateness of the formula used to compute the victim’s expected years of support (life expectancy of 33⅓ years versus a set number of years).
The determination of the proper rate for calculating the damages which hinged on the victim’s net earning capacity, specifically excluding his personal living and incidental expenses.
The overall propriety of awarding damages (including statutory penalties, medical/burial expenses, and attorney's fees) based on the losses sustained by the dependents and heirs.

The respondents argued that the life expectancy of the victim was an essential factor in computing the damages because it reflected the period over which support would be lost.
The petitioner maintained that the application of the American Expectancy Table alongside the victim’s net earning capacity was incorrect, advocating instead for a fixed computation period as argued in other cases like Alcantara.