G.R. No. 159108 - Gold Line Tours, Inc. vs. Heirs of Lacsa

Case Summary (G.R. No. 159108)

Petitioner

Gold Line Tours, Inc.

Respondents

Heirs of Maria Concepcion Lacsa, represented by Teodoro Lacsa

Key Dates

August 2, 1993: Fatal collision in Pili, Camarines Sur.
June 30, 1997: RTC decision awarding damages against Travel & Tours Advisers, Inc.
June 11, 1998: CA dismissal of appeal for failure to pay docket fees.
February 24, 2000: Issuance of writ of execution.
August 2 and October 22, 2001: RTC orders dismissing petitioner’s third-party claim and motion for reconsideration.
October 30, 2002: CA decision dismissing certiorari petition.
June 18, 2012: Supreme Court decision affirming the CA.

Applicable Law

1987 Philippine Constitution (post-1990 decision)
Rules of Court (notably Rule 15 on third-party claims; Rule 41 on appeals)
Civil Code provisions on contracts of carriage (Art. 1786)
Doctrine of corporate personality and piercing the corporate veil

Background of the Collision and Initial Suit

A Goldline bus owned by Travel & Tours Advisers, Inc., driven by Rene Abania, collided head-on with a jeepney driven by Alejandro Belbis on August 2, 1993. A metal part from the jeepney killed passenger Ma. Concepcion Lacsa. Her heirs filed Civil Case No. 93-5917 in the RTC of Sorsogon against Travel & Tours Advisers, Inc. and Abania, alleging negligent breach of the contract of carriage.

Trial Court Findings and Judgment

The RTC applied Civil Code Article 1786, presuming negligence on the part of the carrier once breach of the carriage contract was established. Plaintiffs proved that the bus driver had been inattentive (glancing at a video monitor) and was overtaking recklessly when the collision occurred. Defendants’ evidence blaming the jeepney driver failed to rebut the presumption. On June 30, 1997, the RTC awarded P266,000 plus costs, dismissed Abania and the third-party complaint against the jeepney operator.

Appellate Proceedings up to Finality

Defendants appealed to the CA but failed to timely pay required fees; the CA dismissed the appeal on June 11, 1998, and the dismissal became final on July 17, 1998. Plaintiffs obtained a writ of execution in early 2000. The sheriff levied a tourist bus (Plate No. NWW-883) allegedly owned by Travel & Tours Advisers, Inc., which prompted contempt proceedings against its officer, William Cheng.

Petitioner’s Third-Party Claim and RTC Orders

In a verified third-party claim (April 20, 2001), Gold Line Tours, Inc. asserted it alone owned the bus and was not liable under Civil Case No. 93-5917. Respondents opposed, invoking the doctrine of piercing the corporate veil. On August 2, 2001, the RTC dismissed the third-party claim, finding that both corporations were managed and owned by the same persons (notably William Cheng and his family members) and known interchangeably as “Goldline” in Sorsogon. A motion for reconsideration was denied on October 22, 2001.

CA’s Certiorari Decision

Petitioner filed a certiorari petition in the CA, alleging grave abuse of discretion by the RTC. On October 30, 2002, the CA affirmed the RTC orders, emphasizing:

Admission by William Cheng that the defendant carrier operated sixty Goldline buses.
Overlapping incorporators and officers in both corporations.
No objection was made earlier that the wrong corporate entity had been sued.
The CA concluded the two corporations were one and the same and that the levy was proper. A motion for reconsideration was denied on June 25, 2003.

Supreme Court Issue

Whet