Case Summary (G.R. No. 228107)
Allegations and Defenses
On April 10, 1985, the respondents filed their complaint, claiming damages amounting to approximately P210,000 due to George's hospitalization, which his parents financed. In response, the petitioner argued that George himself was at fault for his injuries, suggesting that he had jumped from the moving bus without warning. Furthermore, Baliwag Transit filed a Third-Party Complaint against Fortune Insurance & Surety Company for its liability insurance coverage.
Release of Claims and Court Proceedings
Subsequent to the complaint, on May 16, 1985, George executed a "Release of Claims" after receiving P8,020.50 from Fortune Insurance. This document intended to absolve both Baliwag Transit and Fortune Insurance from further liabilities related to the incident. However, both Baliwag and Fortune Insurance filed Motions to Dismiss, asserting that the Release of Claims was binding, leading to an initial denial by the Trial Court due to its timing after the Answers had been filed.
Regional Trial Court Decision
The Regional Trial Court of Bulacan dismissed the complaint, asserting that George, being of legal age, had the capacity to execute the Release of Claims, thereby discharging both Baliwag and Fortune from liability. The court maintained that, as the contract of carriage existed solely between Baliwag and George, the parents of George were not recognized as parties to the contract, thus rendering them unable to challenge the validity of the Release.
Appellate Court Ruling
On October 22, 1987, the Court of Appeals reversed the Regional Trial Court's decision, determining that the Release of Claims could not serve as a valid basis for dismissal, as it lacked the consent of George's parents, who had a financial interest due to expenses incurred for their son. The Appellate Court mandated a trial on the merits and instructed George to return the payment to Fortune Insurance.
Supreme Court Analysis
In reviewing the case, the Supreme Court emphasized the validity of the Release of Claims executed by George, noting that he had the legal capacity to act on his behalf and thus discharge any claims against the carrier. The Court further establi
...continue readingCase Syllabus (G.R. No. 228107)
Case Background
- On April 10, 1985, a complaint for damages was filed by the Spouses Sotero Cailipan, Jr. and Zenaida Lopez, along with their son George L. Cailipan, against Baliwag Transit, Inc. for breach of contract of carriage.
- The complaint stemmed from an incident on December 17, 1984, where George, a paying passenger, suffered serious injuries after being thrown off a moving Baliwag bus driven by Leonardo Cruz, who was alleged to be negligent.
- The Cailipan family incurred medical expenses totaling approximately P200,000.00, in addition to around P10,000.00 for incidental costs.
Petitioner’s Response
- Baliwag Transit filed an answer on April 26, 1985, asserting that George's injuries were the result of his own actions, as he allegedly stood up and jumped off the bus despite warnings from the driver.
- The company also initiated a Third-Party Complaint against Fortune Insurance & Surety Company, Inc., claiming limited liability under the insurance policy.
Motions and Rulings
- Both Baliwag and Fortune Insurance sought to dismiss the complaint on the grounds that George had executed a "Release of Claims" on May 16, 1985, for P8,020.50.
- The trial court denied these motions on January 13, 1986, stating they were filed late, after the answers were already submitted.
Amendments and Opposition
- On February 5, 1986, Baliwag was allowed to amend its answer to include the affirmativ