Case Summary (G.R. No. 116110)
Accident Details
On July 31, 1980, Leticia Garcia and her five-year-old son Allan boarded a Baliwag Transit bus driven by Jaime Santiago, which was headed to Cabanatuan City. During the journey, at Malimba, Gapan, Nueva Ecija, the bus collided with a cargo truck parked on the shoulder of the highway. The truck driver was in the process of changing a flat tire, and a kerosene lamp was the only warning about the truck's presence. The accident resulted in the instant deaths of both the bus driver Santiago and his helper, injuries to several passengers, including severe injuries to Leticia and Allan.
Legal Proceedings
The Garcias filed a lawsuit against Baliwag Transit, A & J Trading, and Recontique in the Regional Trial Court of Bulacan, alleging damages due to the breach of contract of carriage and negligence. The trial court found all defendants liable, underscoring Baliwag's failure to ensure the safe transportation of its passengers and A & J Trading's non-compliance with legal requirements for warning devices on the truck.
Trial Court's Findings and Awards
The Regional Trial Court awarded substantial damages to the Garcia spouses including P25,000 for hospitalization, P450,000 for loss of earnings over eight years, P2,000 for Allan’s hospitalization, P50,000 as moral damages, and P30,000 for attorney's fees. This ruling was based on the established negligence attributed to the bus driver.
Court of Appeals' Decision
Upon appeal, the Court of Appeals modified the trial court’s ruling by absolving A & J Trading from liability, reducing the award for attorney's fees to P10,000, and loss of earnings to P300,000. Baliwag petitioned for review, questioning the absolution of A & J Trading and the appropriateness of damage awards.
Standard of Care for Common Carriers
The Supreme Court ruled that as a common carrier, Baliwag had a legal obligation to ensure the safety of its passengers. The presumption of negligence applied, given the injuries sustained by the Garcias, which were unrefuted by evidence of extraordinary diligence by Baliwag in the operation of the bus. Testimonies and evidence indicating the bus driver's recklessness, such as driving at high speeds and conversing while driving, reinforced Baliwag’s liability.
Compliance with Warning Device Regulations
Baliwag contested the assertion that A & J Trading and Recontique were liable due to inadequate warning devices. However, the Court found that the kerosene lamp provided by Recontique was an acceptable warning device under the law, which acknowledges various forms of warnings beyond triangular reflectors. Thus, A & J Trading could not be deemed negligent in this instance.
Review of Damage Awards
The Court further re
...continue readingCase Syllabus (G.R. No. 116110)
Case Citation
- 326 Phil. 762; 93 OG No. 23, 3510 (June 9, 1997)
- G.R. No. 116110, decided on May 15, 1996
Parties Involved
- Petitioner: Baliwag Transit, Inc.
- Respondents:
- Court of Appeals
- Spouses Antonio Garcia & Leticia Garcia
- A & J Trading
- Julio Recontique
Background of the Case
- Leticia Garcia and her five-year-old son, Allan, boarded Baliwag Transit Bus No. 2036, driven by Jaime Santiago, bound for Cabanatuan City on July 31, 1980.
- The bus collided with a cargo truck parked on the highway, resulting in the death of the bus driver and a helper, as well as injuries to several passengers, including Leticia and Allan.
- Leticia sustained severe injuries, including a fractured pelvis and leg, while Allan also suffered a broken leg.
Legal Proceedings
- The Garcia spouses filed a lawsuit against Baliwag Transit, A & J Trading, and Julio Recontique for damages in the Regional Trial Court of Bulacan.
- Both Baliwag and A & J Trading disclaimed responsibility, blaming each other for the accident.
- The trial court found all defendants liable, awarding the Garcia spouses damages including hospitalization fees, lost earnings, and moral damages.
Court of Appeals Decision
- The Court of Appeals modified the trial court's ruling by absolving A & J Trading of liability and reducing the awarded damages.
- Baliwag filed a petition for review challenging the absolution of A & J Trading and the amount of damages awarded.
Issues Raised
- Primary Issues:
- Whether the Court