Case Summary (G.R. No. L-21486)
Applicable Law and Lower Court Decisions
The case involves the application of laws governing common carriers under the Civil Code of the Philippines, particularly Articles 1764 and 2206, which impose an obligation on common carriers for the safety of their passengers. The Court of First Instance of Bulacan found the petitioner liable to pay actual damages, compensatory damages, moral damages, and attorney’s fees to the respondents. The Court of Appeals affirmed this decision.
Issues for Review
The petitioner raised two primary points for reconsideration:
- Whether the tire blowout that caused the accident should be considered a fortuitous event (caso fortuito) exempting the petitioner from liability.
- Whether the petitioner could legally be held liable for moral damages in this context.
Discussion on Liability for the Tire Blowout
Petitioner argued that the tire explosion was a fortuitous event and thus no negligence could be imputed. They cited prior Court of Appeals rulings which held that a tire blowout alone, without evidence of negligence, did not establish liability. However, the Supreme Court distinguished the present case on factual grounds, noting that the cause of the blowout was identified as a mechanical defect: the inner tube was pinched between the wheel’s inner circle and a slipped rim.
This defect, the Court reasoned, was evidence of inadequate maintenance or faulty equipment—conditions the bus company could have discovered and remedied with proper inspection before departure. Additionally, the Court found the bus was traveling at a high speed, further aggravating the circumstances leading to the accident. Given these facts, the Court rejected the characterization of the blowout as a fortuitous event, holding that negligence was sufficiently demonstrated.
Recovery of Moral Damages
The Supreme Court confirmed the well-established principle under Philippine law that moral damages are recoverable by passengers or their heirs in cases where a common carrier breaches its contract of carriage leading to death or injury. Articles 1764 and 2206 of the Civil Code specifically provide for this liability.
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Case Background and Procedural History
- This is an appeal by certiorari filed by La Mallorca and Pampanga Bus Company, Inc. (commonly known as La Mallorca-Pambusco) challenging the decision of the Court of Appeals.
- The Court of Appeals had affirmed the decision of the Court of First Instance of Bulacan in Civil Case No. 2100 entitled "Valentin de Jesus and Manolo Tolentino vs. La Mallorca-Pambusco."
- The lower courts ruled against the petitioner (La Mallorca-Pambusco), ordering them to pay actual damages, compensatory damages, moral damages, and counsel fees to the plaintiffs Valentin de Jesus and Manolo Tolentino.
- The petitioner raised two main errors on appeal: (1) the liability for the accident caused by a blowout of one of the bus tires should be considered a case of “caso fortuito” (fortuitous event), thus exonerating them from negligence; and (2) the imposition of moral damages against the petitioner was improper.
Facts of the Case
- The case arose from the death of Lolita de Jesus, aged 20, who was the daughter of Valentin de Jesus and wife of Manolo Tolentino.
- Lolita de Jesus was a passenger on the petitioner’s bus, which was involved in a head-on collision with a freight truck traveling in the opposite direction.
- The accident occurred in the morning of October 8, 1959, in a barrio in Marilao, Bulacan.
- The immediate cause of the accident was the driver of the bus losing control of the wheel due to the sudden explosion of the bus’s left front tire.
- Petitioner contends that the tire blowout constitutes a fortuitous event and therefore should not result in liability.
Issue on Liability Arising from Tire Blowout
- The petitioner asserted that tire blowouts are fortuitous events, thus negating any negligence on their part.
- The petitioner relied on prior Court of Appeals rulings, namely Rodriguez vs. Red Line Transportation Co. and People vs. Palapad, which suggested no liability attached to tire blowouts absent negligence.
- However, the Supreme Court distinguished these cases on grounds that those rulings did not involve specific findings of negligence or causative factor