Case Summary (G.R. No. 182356)
Key Dates
- March 30, 2000: Vehicular collision at North Avenue, Quezon City.
- June–October 2000: Onset of whiplash symptoms; three months of physical therapy; cervical spine surgery on October 19, 2000.
- May 8, 2001: Complaint for damages filed in RTC, Quezon City.
- April 19, 2007: RTC decision in favor of petitioner.
- February 11, 2008: Court of Appeals decision reversing RTC.
- March 31, 2008: CA resolution denying motion for reconsideration.
- December 4, 2013: Supreme Court decision under review.
Applicable Law
- 1987 Philippine Constitution (jurisdictional basis, due process).
- Civil Code of the Philippines:
• Article 2176 (quasi-delict; liability for negligence).
• Article 2180(5) (employer’s vicarious liability for employees acting within scope of assigned tasks). - Rules of Court:
• Rule 45 (certiorari; review of CA decisions with conflicting RTC findings).
• Rule 129, Section 2 (judicial notice).
• Rule 130 (rules on evidence and expert testimony). - Relevant Jurisprudence: Nutrimix Feeds Corp. v. CA; GSIS v. Ibarra; Carvajal v. Luzon Development Bank.
Factual Background
- The petitioner’s brother, Juan dela Llana, stopped at a red light on North Avenue when Joel’s gravel-laden dump truck suddenly rammed the rear of their car.
- Dra. dela Llana suffered glass splinter wounds and later experienced escalating pain in her left neck and shoulder.
- After unsuccessful physical therapy under Dr. Rosalinda Milla, she underwent cervical spine surgery by Dr. Eric Flores to relieve nerve compression between C5 and C6.
Trial Court Findings (RTC)
- Determined that Joel’s reckless driving proximately caused petitioner’s whiplash injury.
- Held respondent vicariously liable for failing to exercise the diligence of a good father of a family in hiring and supervising Joel.
- Awarded P570,000.00 actual damages, P250,000.00 moral damages, and costs.
Court of Appeals Ruling
- Reversed the RTC for lack of proof linking collision to whiplash injury by preponderance of evidence.
- Noted the lengthy interval between accident and symptom onset raised reasonable doubt.
- Emphasized absence of immediate medical examination and the petitioner’s failure to present expert witnesses or establish causation in her medical certificate.
Issue before the Supreme Court
Whether Joel Primero’s negligent driving was the proximate cause of Dra. dela Llana’s whiplash injury and, consequently, whether respondent is vicariously liable.
Supreme Court Analysis
- Quasi-delict Elements (Art. 2176):
– Existence of damages.
– Fault or negligence.
– Direct causal connection between negligence and damages. - Burden of Proof:
– Lies with petitioner to establish causation by preponderance of evidence. - Scope of Review:
– CA findings of fact are generally conclusive under Rule 45 unless conflicting with RTC.
– Here, a conflict permitted examination of evidence. - Evaluation of Evidence:
a. Photographs of the damaged car only prove impact, not medical causation.
b. Medical certificate inadmissible (not f
Case Syllabus (G.R. No. 182356)
Factual Antecedents
- On March 30, 2000 at around 11:00 p.m., Juan dela Llana drove a 1997 Toyota Corolla along North Avenue, Quezon City, with Dra. Leila dela Llana seated in front and a companion at the back.
- The car stopped at a red light near Veterans Memorial Hospital when a dump truck loaded with gravel and sand suddenly rammed into its rear, collapsing the bumper and shattering the rear windshield.
- Glass fragments punctured Dra. dela Llana, causing minor wounds; no other visible injuries were noted on scene.
- Traffic investigators identified the truck driver as Joel Primero and described his conduct as recklessly imprudent.
- Joel admitted Rebecca Biong, doing business as Pongkay Trading, was his employer in the gravel and sand business.
- In early May 2000, Dra. dela Llana began experiencing progressive neck and shoulder pain on the left side, culminating in loss of mobility of her left arm.
- On June 9, 2000, she consulted Dr. Rosalinda Milla, who diagnosed a whiplash injury with nerve compression and prescribed three months of physical therapy without relief.
- Subsequent consultations with Drs. Lopez, Cabral-Lim, and Flores led to cervical spine surgery between C5 and C6 on October 19, 2000; surgery relieved nerve impingement but did not restore her professional capacity.
- On October 16, 2000, Dra. dela Llana demanded compensation from Rebecca Biong, who refused payment.
- On May 8, 2001, Dra. dela Llana filed suit in the Regional Trial Court, Quezon City, claiming P150,000 for medical expenses, P30,000 monthly income loss since June 2000, plus actual, moral, exemplary damages, and attorney’s fees.
Trial Proceedings and Evidence
- Dra. dela Llana testified as an ordinary witness; Joel Primero was declared a hostile witness.
- Dra. dela Llana introduced a medical certificate dated November 20, 2000 from Dr. Milla, diagnosing whiplash injury.
- Joel testified the truck’s brakes had gotten stuck, causing the collision.
- Rebecca Biong testified that Dra. dela Llana appeared physically fit days after the accident and detailed her due diligence in selecting and supervising Joel (moral-character clearances, driving tests by mechanic Alberto Marcelo).
- Marcelo testified the truck was in good working condition that morning