Case Summary (G.R. No. 161946)
Facts of the Case
Eyewitness Rosalinda Palero reported that shortly after 4:00 PM, Respondent Macas was standing on the shoulder of the road when he was struck and run over by a Ford Fiera vehicle. Following the accident, Cimafranca transported the victim to Davao Medical Center, where orthopedic surgeon Dr. Hilario Diaz treated him for severe injuries, ultimately leading to the amputation of both of Macas's legs. The vehicle involved was registered in the name of Petitioner Cadiente, who claimed he had sold it two months prior to the accident.
Trial Court Proceedings
The victim's father subsequently filed a complaint for torts and damages against both Cimafranca and Cadiente. Cadiente then filed a third-party complaint against the alleged buyer, Engr. Rogelio Jalipa. After the trial, the Regional Trial Court (RTC) ruled that both Cadiente and Jalipa were jointly and severally liable for the damages resulting from their negligence. The damages awarded included P300,000 for compensatory damages, P150,000 for moral damages, P18,982.85 for medical expenses, P30,000 for attorney's fees, and additional costs.
Court of Appeals Decision
On appeal, the Court of Appeals affirmed the RTC's decision, confirming the lower court's findings were consistent with the evidence presented. The appeal was denied, and the ruling regarding joint and several liability between Cadiente and Jalipa stood.
Supreme Court Appeal
Cadiente appealed to the Supreme Court, asserting that the Court of Appeals made serious legal errors. He raised issues of contributory negligence on the part of the injured party and questioned the joint and several liability rulings against him and Jalipa.
Legal Standards and Consideration
The Supreme Court reiterated the principle of contributory negligence as outlined in Article 2179 of the Civil Code. The standard dictates that when a plaintiff’s negligence is a contributory factor, their potential recovery may be mitigated. However, if the plaintiff is found to be without negligence, the defendant remains entirely liable.
Determination of Contributory Negligence
The Court found that at the time of the accident, Macas was situated legally on the shoulder of the highway, designated for pedestrian use. Evidence indicated that Cimafranca's reckless driving—involving swerving onto the shoulder—was the proximate cause of the injuries. Thus, the Court rejected Petitioner’s argument of contributory negligence, concluding that the victim was not at fault for the accident.
Liability of Vehicle Owner
The
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Case Background
- The case involves a review on certiorari concerning the Decision dated September 16, 2002, and the Resolution dated December 18, 2003, from the Court of Appeals in CA-G.R. CV No. 64103.
- The dispute arose from an incident on July 19, 1994, where 15-year-old high school student Bithuel Macas was struck and run over by a Ford Fiera driven by Chona C. Cimafranca.
- The vehicle was registered under the name of Atty. Medardo Ag. Cadiente, the petitioner.
Incident Details
- Eyewitness Rosalinda Palero testified that she witnessed the accident from about two and a half meters away.
- Following the incident, Macas was rushed to Davao Medical Center, where he underwent surgery due to severe injuries, including the amputation of both legs up to the groins.
- Cimafranca, the driver, absconded after the incident.
Legal Proceedings
- Macas's father, Samuel Macas, filed a complaint for torts and damages against Cimafranca and Cadiente in the RTC of Davao City.
- Cadiente filed a third-party complaint against Engr. Rogelio Jalipa, claiming he had sold the vehicle prior to the accident.
- Jalipa, in response, filed a fourth-party complaint against Abraham Abubakar, claiming he had sold the vehicle to him.
Trial Court Decision
- The RTC ruled that both Cadiente and Jalipa were jointly and seve