Title
Dela Cruz vs. Octaviano
Case
G.R. No. 219649
Decision Date
Jul 26, 2017
Drunk driver Al Dela Cruz caused a tricycle collision, severely injuring Renato Octaviano. The Supreme Court affirmed his negligence, holding him and vehicle owner solidarily liable for damages.

Case Summary (G.R. No. 219649)

Procedural Posture

The plaintiffs (Renato and Wilma Octaviano) sued petitioner Al Dela Cruz and the vehicle owner for damages. The Regional Trial Court (Branch 275, Las Piñas City) dismissed the complaint. The Court of Appeals reversed, holding petitioner and the vehicle owner solidarily liable and awarding actual, moral, exemplary damages and attorney’s fees. Petitioner sought review under Rule 45; the Supreme Court denied the petition and affirmed the Court of Appeals.

Facts Established at Trial

At about 9:00 p.m. on April 1, 1999, Renato, his mother Wilma, and sister Janet rode a tricycle driven by Eduardo Padilla. While proceeding on Naga Road, an oncoming car driven by petitioner struck the rear portion of the tricycle. The impact threw Renato into the gutter; his right leg was crushed and amputated below the knee that same night. Renato underwent prolonged hospitalization and rehabilitation, multiple operations for bone infection, and later obtained a prosthetic limb at his own expense. Total medical and prosthetic expenses amounted to P623,268.00. The tricycle was towed from the scene; witnesses removed the car’s license plate, and bystanders reported that the car’s driver appeared intoxicated.

Evidence Presented

  • Eyewitnesses S/Sgt. Joselito Lacuesta and Antonio Fernandez testified they saw the collision, assisted the injured, put Renato into the car, observed the driver’s apparent intoxication, and observed others seize the car’s license plate. Lacuesta specifically instructed the car’s driver to carry the injured to the hospital.
  • Petitioner testified he had borrowed Dr. Isagani Cirilo’s Honda Civic to fetch his mother from church and that he saw a parked Elf van and a tricycle ahead, flashed his lights, and slowed, but the tricycle suddenly accelerated and the two vehicles collided. He stated he stopped, had the injured loaded into his car, stopped at his house briefly, then took them to a clinic and later to Perpetual Help Hospital.
  • Imelda Cirilo corroborated that petitioner borrowed their car and that she signed the hospital admission slip for Renato but denied giving financial assistance.
  • Traffic enforcer Renato Martinez testified he arrived after vehicles had left; he later encountered petitioner at the hospital and escorted him per instructions.
  • Police spot investigation report (SPO2 Soriano) stated Vehicle-2 (the Honda Civic) swerved to avoid hitting a tricycle and sideswiped Vehicle-1 (tricycle). The report described Vehicle-2 as “Positive for Alcoholic Breath (AB).”

Issues Raised by Petitioner on Appeal

Petitioner argued, principally, that: (1) he was not negligent; (2) the Court of Appeals’ factual findings were unsupported by evidence; (3) the tricycle driver’s fault or gross negligence was the proximate cause; and (4) the CA overlooked undisputed facts that would justify a different conclusion. He also contended the police report should not have been relied upon absent confrontation or cross-examination of the investigating officer and denied being drunk.

Legal Standards Applied

  • Negligence: The Court applied the well-established definition—failure to exercise the degree of care which the circumstances demand—and applied the “reasonable person”/paterfamilias standard (Picart v. Smith). Liability under Article 2176 (quasi-delict) requires proof of damage, fault or negligence, proximate cause, and absence of pre-existing contractual relation.
  • Burden and quantum of proof: In civil actions, the party with the burden must prove his case by preponderance of evidence (Section 1, Rule 133). Preponderance means the evidence is more convincing and has greater weight.
  • Exceptions to finality of appellate factual findings: The Court acknowledged established grounds when Supreme Court may review factual findings of the Court of Appeals (e.g., misapprehension of facts, conflicting findings, overlooking undisputed facts).

Court’s Analysis of Negligence and Evidentiary Weight

  • Damage: The Supreme Court accepted as proven the severe injuries to Renato (amputation) and injuries to Wilma; documentary hospital bills supported actual damages.
  • Fault and corroboration: The Court found the Court of Appeals correctly concluded petitioner’s negligence. The police spot report indicating petitioner was “positive for alcoholic breath” was corroborated by eyewitness testimony (Lacuesta and Fernandez) who observed petitioner appeared intoxicated. The Court held that the report’s contents were corroborated by these witnesses and thus entitled to weight despite the absence of testimony by the investigator.
  • Causation and foreseeability: The Court determined petitioner failed to exercise the reasonable foresight and care expected of a prudent driver. The Court found petitioner had adequate opportunity to slow down or stop on seeing the parked van and tricycle at distance; his continued driving and failure to take precaution proximately caused the collision. The fact the tricycle was struck at the rear reinforced that petitioner’s conduct caused the injury.
  • Contributory negligence and third-party driver: The Court rejected petitioner’s contention that the tricycle driver’s negligence or passengers’ violation of a municipal ordinance (excess passengers) constituted proximate contributory negligence sufficient to exculpate petitioner. The Court explained contributory negligence requires a causal link to the injury; the alleged infractions did not establish proximate contribution to the harm. The Court also explained that even if the tricycle driver were negligent, liabilities arise from different sources (contract of carriage for the

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