Title
DST Movers Corp. vs. People's General Insurance Corp.
Case
G.R. No. 198627
Decision Date
Jan 13, 2016
A traffic accident claim against DST Movers was dismissed as the key evidence, a hearsay traffic report, was inadmissible, and repair records proved the truck was not operational.

Case Summary (G.R. No. L-31568)

Procedural Posture and Relief Sought

PGIC filed a Complaint for Sum of Money in the Metropolitan Trial Court (MTC), Civil Case No. 181900, asserting subrogation to Yuboco’s rights and seeking P90,000 (difference between P320,000 paid and P230,000 salvage), plus interest, attorney’s fees and costs. The MTC rendered judgment for PGIC (P90,000 actual damages, 12% interest, P10,000 attorney’s fees). The Regional Trial Court (RTC), Branch 47, affirmed. The Court of Appeals (CA) affirmed in part but reduced actual damages to P25,000 temperate damages. DST Movers filed a Rule 45 petition to the Supreme Court asking reversal of the CA decision and dismissal of PGIC’s complaint.

Facts as Alleged by PGIC and Evidence of Loss

PGIC alleged a rear‑end hit‑and‑run: the Isuzu truck (V3) struck the stationary Honda Civic (V1), which was pushed into a Mitsubishi Lancer (V2). PGIC exhibited a Traffic Accident Investigation Report (Entry No. 805‑285‑0202) prepared by PO2 Tomas and attached photographic evidence of damage, the insurance policy (Private Car Policy No. HAL‑PC‑1314), vouchers showing PGIC’s P320,000 payment to Yuboco, and documents showing salvage at P230,000. PGIC claimed subrogation and demanded the P90,000 difference from DST Movers, but DST Movers did not pay.

Petitioner’s Denial and Documentary Defense

DST Movers admitted ownership of the truck but denied it made any trip on February 28, 2002, asserting the truck was under repairs and maintenance on that date. DST Movers attached invoices, receipts, and cash vouchers as Annexes 1–1F evidencing repairs and maintenance on specific dates including February 28, 2002, to support that the truck could not have been at SLEX that night.

Central Legal Issue Presented

Whether DST Movers’ liability was established by a preponderance of evidence, and whether the MTC (and consequently the RTC and CA) erred in admitting and assigning probative weight to the Traffic Accident Investigation Report prepared by PO2 Tomas, which was the principal basis for identifying DST Movers’ vehicle as responsible.

Standard of Review — Rule 45 and Questions of Fact vs. Law

The petition was brought under Rule 45 (1997 Rules of Civil Procedure); Rule 45 limits Supreme Court review predominantly to questions of law. Determination of preponderance of evidence is a question of fact because it requires weighing credibility and the relative probative value of competing evidence. Ordinarily, findings of fact of the trial court affirmed by the CA are conclusive on the Supreme Court, subject to recognized exceptions (e.g., findings based on conjecture, misapprehension of facts, grave abuse of discretion, conflicting findings, findings unsupported by citation to specific evidence, or when the CA’s findings are premised on supposed absence of evidence contradicted by the record).

Hearsay Rule and Exception for Entries in Official Records

Rule 130, Section 36 (Revised Rules on Evidence) generally excludes hearsay — out‑of‑court statements offered for the truth of the matters asserted. Section 44 provides an exception for entries in official records: entries made by a public officer in the performance of duty are prima facie evidence of the facts therein stated, but only if three requisites are met: (a) made by a public officer (or person specially enjoined by law); (b) made in the performance of duty; and (c) the public officer had sufficient knowledge of the facts he stated, acquired personally or through official information.

Application of the Hearsay Doctrine to the Traffic Accident Report

The Report was drafted by PO2 Tomas and explicitly recites that the factual account—identifying the truck as V3 and describing the hit‑and‑run—was reported to PO2 Tomas by “G. Simbahon of PNCC/SLEX.” Accordingly, the Report’s factual assertions identifying the responsible vehicle and driver derive not from PO2 Tomas’ personal knowledge but from a third‑party report. The third requisite for admissibility under Section 44 (sufficient knowledge acquired personally or by official information) was thus not satisfied because the report’s critical facts were not shown to have been personally known or officially obtained by PO2 Tomas.

Failure to Present Witnesses or Affidavits Supporting the Report

Neither PO2 Tomas nor G. Simbahon testified in court. Under the Revised Rule on Summary Procedure applicable to the MTC proceedings, parties were required to submit affidavits of witnesses with their position papers (Section 9), since no trial testimony would be taken after the preliminary conference. PGIC, however, only annexed the Traffic Accident Investigation Report to its position paper and did not submit an affidavit by PO2 Tomas. Because the Report stood alone without the investigating officer’s affidavit or the testimony/affidavit of the person who allegedly observed or reported the incident (G. Simbahon), the Report was hearsay and inadmissible as proof of the

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