Case Summary (G.R. No. 150157)
Petitioners and Respondent
Petitioners: Mauricio Manliclic (driver) and PRBLI (employer), sued for negligence and vicarious liability.
Respondent: Modesto Calaunan, seeking damages for vehicular destruction and personal injuries.
Key Dates and Vehicles Involved
On July 12, 1988, at approximately Kilometer 40 on the North Luzon Expressway in Bulacan, PRBLI Bus No. 353 (plate CVD-478) collided with respondent’s jeep (plate PER-290). The criminal case commenced in 1989; the civil case was filed December 2, 1991.
Facts of the Collision
Both vehicles traveled southbound on a straight, paved, fair-weather expressway. The bus overtook the jeep and struck its rear left side, sending the jeep off-road into a ditch. The bus stopped about 7–8 meters beyond impact. Respondent sustained minor injuries; his driver was unhurt.
Medical and Criminal Proceedings
Respondent received treatment first at Manila Central University Hospital, then at Veterans Memorial Medical Center. Criminal Case No. 684-M-89 for reckless imprudence resulting in damage and physical injuries was filed against Manliclic. In 2001 the Court of Appeals acquitted him.
Civil Proceedings and Admission of Former Testimony
Respondent’s civil complaint (Civil Case No. D-10086) alleged negligence by Manliclic and vicarious liability by PRBLI. Transcripts of stenographic notes (TSNs) from the criminal trial were offered under Rule 130, Section 47. PRBLI failed to object at the time, waiving any hearsay or procedural defects.
Trial Court Findings on Liability
The Regional Trial Court favored respondent’s account over petitioners’. It noted inconsistencies in Manliclic’s statements and the absence of evidence supporting his version. Finding Manliclic negligent in bus operation, it invoked Article 2180 of the Civil Code to impose vicarious liability on PRBLI.
Court of Appeals Decision
In CA-G.R. CV No. 55909, the Court of Appeals affirmed the RTC decision in all respects, upholding evidence rulings, credibility determinations, PRBLI’s due diligence defense rejection, and the damage awards.
Effect of Criminal Acquittal on Civil Quasi-Delict
An acquittal in a criminal case does not extinguish civil liability for quasi-delict under Article 2176 of the Civil Code. Civil liability for negligence remains a distinct concept and may be proven by preponderance of evidence despite penal acquittal.
Employer’s Vicarious Liability and Due Diligence
Article 2180 presumes an employer negligent when an employee causes harm unless the employer proves diligence in selection and supervision. PRBLI established hiring
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Facts
- Two vehicles involved:
• Philippine Rabbit Bus No. 353 (plate CVD-478) owned by Philippine Rabbit Bus Lines, Inc. (PRBLI), driven by Mauricio Manliclic.
• Owner-type jeep (plate PER-290) owned by Modesto Calaunan, driven by Marcelo Mendoza. - On July 12, 1988 (6:00–7:00 AM), both vehicles were southbound on the North Luzon Expressway (NLEX), Kilometer 40, Barangay Lalangan, Plaridel, Bulacan.
- Collision occurred when the bus struck the rear left side of the jeep, forcing it off the road into a ditch; the bus veered left and stopped 7–8 meters from impact.
- Respondent Calaunan sustained minor injuries; driver Mendoza was unhurt.
- Criminal case (Crim. Case No. 684-M-89) for reckless imprudence with damage and physical injuries was filed against Manliclic before RTC Malolos, Bulacan.
- Civil case (Civil Case No. D-10086) for damages was filed by Calaunan against Manliclic and PRBLI before RTC Dagupan City.
- Parties admitted capacity to sue, venue, vehicle identities, driver licensure, date/place of collision, weather and road conditions, direction of travel.
- Dispute centered on how collision occurred:
• Respondent’s version: bus overtook jeep and, while still behind, hit its rear.
• Petitioners’ version: bus was alongside jeep preparing to overtake when jeep suddenly swerved left to pass another jeep.
Procedural History
- RTC Dagupan City rendered judgment (July 22, 1996) holding petitioners jointly and solidarily liable for P40,838.00 (actual damages), P100,000.00 moral damages, P100,000.00 exemplary damages, P15,000.00 attorney’s fees, plus costs.
- Petitioners appealed to the Court of Appeals (CA-G.R. CV No. 55909); CA affirmed RTC decision (September 28, 2001).
- Petitioners elevated the case to the Supreme Court via petition for review on certiorari.
- During appeal pendency, respondent Calaunan died; his wife and children were substituted.
Issues
- Whether the TSNs and other documents from the criminal case were improperly admitted in the civil suit in violation of Section 47, Rule 130 of the Rules of Court.
- Whether the CA erred in relying on respondent’s version of the accident and in rejecting petitioners’ version.
- Whether PRBLI proved due diligence as employer in selection and supervision of its driver to rebut presumption of vicarious liability under Article 2180, New Civil Code.
- Whether Manliclic’s acquittal in the criminal case extinguishes or affects his civil liability for quasi-del