Case Summary (G.R. No. L-384)
Facts of the Case
On January 12, 1958, a parked passenger jeepney was struck from behind by a speeding motor truck, leading to the deaths of three passengers and injuries to two others, necessitating hospitalization. Subsequently, lawsuits were filed in February 1958 by the representatives of the deceased and injured parties against both the truck and jeepney drivers, as well as their respective owners. At the trial court level, the jeepney driver and owners were absolved from liability, whereas the truck driver and owners were ordered to compensate the victims.
Court of Appeals Decision
The Court of Appeals reviewed the case and upheld the trial court's exoneration of the jeepney driver and owners. Although it acknowledged that the jeepney driver was at fault for improper parking—which contributed to the incident—it determined that the truck driver bore greater negligence leading to the collision. The appellate court imposed damages on the truck driver and its owners but did not hold the jeepney driver and owners liable.
Supreme Court Analysis
The Supreme Court granted a petition for review upon finding potential errors in the appellate court's judgment. It noted that the obligation of a common carrier, as stipulated in the New Civil Code, requires them to exercise utmost diligence for the safety of their passengers. The court reiterated that carriers are presumed negligent unless they prove otherwise. The jeepney driver was confirmed to be negligent for improperly parking, implying that the jeepney owners should also be held liable for the injuries incurred by their passengers.
Rationale for Joint Liability
The Supreme Court concluded that it was inequitable to exempt the jeepney driver and owners from liability solely because the truck driver was also negligent. The principle of "last clear chance" applicable in disputes between negligent drivers did not absolve the carrier's obligation toward its passengers. Thus, the jeepney driver and owners were found liable, alongside the truck driver and owners, for the damages awarded in the lower court rulings.
Conclusion on Damages
The court did not alter the damage amounts assessed against the truck driver and owne
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Case Background
- On January 12, 1958, a passenger jeepney was parked on the road to Taal, Batangas.
- A speeding motor truck collided with the jeepney from behind, resulting in the deaths of three passengers.
- Two additional passengers sustained injuries that necessitated hospitalization.
- In February 1958, legal actions were initiated by the representatives of the deceased and injured parties against the truck driver, the truck owners, and the jeepney driver and owners.
Initial Court Ruling
- The Batangas Court of First Instance absolved the jeepney driver and owners from liability for damages.
- The court found the truck driver and owners liable for compensation to the plaintiffs.
Appeal to the Court of Appeals
- The plaintiffs appealed, asserting that the jeepney driver and owners should also be held responsible for damages.
- The Court of Appeals reviewed the case and confirmed that the jeepney was overloaded, carrying 14 to 16 passengers, exceeding its maximum capacity of 11.
- The jeepney driver, Pepito Buno, parked partially on the road, contributing to the accident.
- The Appellate Court found the truck driver to have committed greater negligence, leading to the collision.
- The court ruled based on