Case Summary (G.R. No. 74387-90)
Case Overview
This document summarizes the Supreme Court decision in G.R. No. 74387-90, dated November 14, 1988, concerning a petition for review by certiorari filed by Batangas Laguna Tayabas Bus Company (BLTB) and its driver Armando Pon against the Intermediate Appellate Court (IAC) and the heirs of deceased passengers.
Background Facts
- Incident: A collision occurred on August 11, 1978, between BLTB Bus No. 1046, driven by Armando Pon, and Superlines Bus No. 404, driven by Ruben Dasco, on a highway in Tayabas, Quezon.
- Casualties: The accident resulted in the deaths of Aniceto Rosales, Francisco Pamfilo, and Romeo Neri, along with injuries to Nena Rosales and Baylon Sales, all passengers of the BLTB bus.
- Legal Actions: Separate cases were initiated against BLTB and Superlines, with the trial court finding BLTB and Pon solely responsible for the damages.
Court Findings
- Negligence: The Court found that Pon's negligence in overtaking a vehicle in a no-overtaking zone was the proximate cause of the collision.
- Liability: The trial court exonerated Superlines and Dasco, attributing liability solely to BLTB and Pon.
Legal Principles
- Culpa Contractual vs. Culpa Aquiliana:
- The appellate court found that the petitioners were liable under both culpa contractual (contractual fault) and culpa aquiliana (tort).
- Key Definitions:
- Culpa Contractual: Liability arising from breach of contract obligations, specifically for common carriers to provide safe transport.
- Culpa Aquiliana: Liability based on tort law, focusing on negligent actions resulting in damage.
Responsibilities of Common Carriers
- Standard of Care: Common carriers, such as BLTB, are required to exercise "utmost diligence" in transporting passengers safely, as stipulated in Articles 1755 and 1756 of the Civil Code.
- Presumption of Negligence: A common carrier is presumed negligent unless they can prove extraordinary diligence in preventing accidents.
Defense Arguments
- Claim of No Liability: Petitioners argued that the plaintiffs should have limited their claims to BLTB and Pon if the basis was culpa contractual and contended that the accident was due to force majeure.
- Court's Rejection of Defense: The Court found insufficient evidence to support the defense of force majeure since the accident was due to Pon's reckless driving.
Conclusion
- The Supreme Court affirmed the appellate court’s decision, maintaining the liability of BLTB and Pon for the damages resulting from the collision.
Key Takeaways
- The ruling emphasizes the stringent liability st...continue reading
Case Syllabus (G.R. No. 74387-90)
Case Overview
- This case involves a petition for review by certiorari concerning a decision rendered by the Intermediate Appellate Court (IAC) which modified and affirmed a joint decision from the trial court.
- The case revolves around a vehicular collision that occurred on August 11, 1978, between a bus operated by Batangas Laguna Tayabas Bus Company (BLTB) and another bus from Superlines Transportation Company.
- The collision resulted in fatalities and injuries to passengers, leading to multiple claims for damages.
Background of the Incident
- The accident occurred on a highway in Barangay Isabong, Tayabas, Quezon.
- BLTB Bus No. 1046, driven by Armando Pon, attempted to overtake a Ford Fiera car while negotiating a bend, leading to a collision with Superlines Bus No. 404, driven by Ruben Dasco.
- The collision resulted in the deaths of three individuals: Aniceto Rosales, Francisco Pamfilo, and Romeo Neri, along with injuries to Nena Rosales (wife of Aniceto) and Baylon Sales.
Legal Proceedings Initiated
- The surviving heirs of the deceased and the injured parties filed separate cases against both bus companies and their respective drivers in the Court of First Instance of Marinduque.
- Criminal cases against the drivers were also initiated in the Court of First Instance of Quezon.
- The defendants denied liability, asserting that they exercised due diligence and shifted blame onto each other.