Case Summary (G.R. No. 74387-90)
Background and Antecedent Facts
The incident was precipitated when BLTB Bus No. 1046, driven by Armando Pon, attempted to overtake a Ford Fiera vehicle while negotiating a dangerous bend in the highway. This maneuver was ill-timed, as Superlines Bus No. 404, operated by Ruben Dasco, was approaching from the opposite direction. The collision led to the deaths of Aniceto Rosales, Francisco Pamfilo, and Romeo Neri, and injuries to passengers Nena Vda. de Rosales and Baylon Sales. In response, the surviving heirs initiated separate civil cases against BLTB and Superlines, as well as criminal proceedings against the drivers.
Trial Court Proceedings
In the lower court, BLTB and its driver were held jointly and severally liable for damages, despite the defendants denying fault and attributing blame to each other. The trial court found the driver of the Superlines bus not liable while placing the blame solely on driver Pon for the negligent operation of the bus. This decision included awarded damages to the plaintiffs due to the fatalities and injuries caused by the collision.
Appeal and Intermediate Appellate Court Ruling
BLTB and Armando Pon appealed the lower court's decision to the Intermediate Appellate Court, contesting the ruling on the basis of liability, specifically arguing that the plaintiffs' claims were improperly grounded on culpa contractual rather than culpa aquiliana (tort). The appellate court modified the lower court's judgment to increase the death indemnity to PHP 30,000 per set of heirs while affirming the overall ruling that held BLTB liable due to the acts of its driver.
Liability Principles
The appellate court determined that liability arose from both contractual and tortious grounds. It underscored that the driver, Armando Pon, acted negligently by overtaking in a no-overtaking zone, thereby failing to adhere to traffic regulations that emphasize the necessity of safety when maneuvering vehicles on the road, especially in a hazardous area. The court cited existing legal precedents regarding the obligations of a driver and common carrier, emphasizing that negligence in this context is typically inferred when a traffic violation occurs.
Rationale for Affirming Liability
In affirming the liability of BLTB, the court relied on provisions from the Civil Code, which place a heightened duty of diligence on common carriers. The burden of proof shifts to the carrier to demonstrate that they have exercised "extraordinary diligence" in preventing harm to passengers. The failure to meet this burden, coupled with demonstrable negligence from the driver, resulted in BLTB being deemed directly liable for the damages incurred by the plaintiffs.
Conclusion on Legal Arguments
The petitioners’ argument that a common carrie
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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.
Trial Court Findings
- The trial court ultimately