Case Summary (G.R. No. 163351)
Facts of the Case
The collision occurred when the petitioner’s bus, traveling southbound, collided with a northbound motorcycle driven by So, with Castro as a passenger. Eyewitnesses, including Julito Dayuday and Florencio Banico, testified that the bus struck the motorcycle after swerving from its lane. Dayuday claimed that the petitioner failed to assist the victims after the accident. The defense included testimonies from police officers and individuals who asserted that the motorcycle had veered into the bus's lane.
Trial Court's Decision
The trial court found the petitioner guilty of reckless imprudence resulting in double homicide and considered his failure to assist the victims as an aggravating circumstance. The court imposed an indeterminate sentence ranging from six months' arresto mayor to six years and one day of prision correccional, alongside substantial civil damages to the heirs of both victims, totaling approximately P3.4 million for So and P2 million for Castro.
Appeal to the Court of Appeals
Petitioner appealed the trial court’s decision, arguing that the evidence presented was inconsistent and excessive regarding the damages awarded. The Court of Appeals modified the trial court's judgment, correcting the length of the imposed penalty and the computation of damages for loss of earning capacity, while affirming the civil liabilities of the petitioner and recognizing the subsidiary liability of Vallacar Transit, Inc.
Issues on Appeal
In the Supreme Court appeal, Nueva España contended that the appellate court's findings were erroneous and that the damages awarded exceeded legal norms. He sought to reverse his reckless imprudence conviction.
Findings of the Supreme Court
The Supreme Court held that it would not typically intervene in factual findings of the lower courts unless substantial errors were shown. It agreed with the lower courts regarding the petitioner’s liability. However, it modified the damages, highlighting the need for concrete evidence for lost earning capacity claims. It ruled that temperate damages could be warranted due to a lack of documentary evidence, thus awarding each victim’s heirs P25,000 for temperate damages instead of full loss of earning capacity.
Compensation and Damages
The Court outlined the damages recoverable following a wrongful death, reaffirming the need to allocate civil indemnity ex delicto to each victim’s heirs without the need for further proof beyond the crime's commission. The amounts awarded for actual damages were also limited due to insufficient docu
...continue readingCase Syllabus (G.R. No. 163351)
Case Background
- The incident occurred on May 15, 1998, at approximately 11:15 a.m., involving a collision between a passenger bus driven by petitioner Antonio E. Nueva EspaAa and a northbound Honda motorcycle.
- The bus, owned by Vallacar Transit, Inc., was traveling southbound towards Dumaguete City when it struck the motorcycle, resulting in the deaths of its riders, Reynard So and Nilo Castro.
- An information was filed against the petitioner for reckless imprudence resulting in double homicide and failing to assist the victims.
Eyewitness Testimonies
- Julito Dayuday testified that he witnessed the collision while waiting for a ride. He described how the bus swerved from its lane into the motorcycle's path, dragging it for about 24 meters and leaving the victims lying on the road.
- Florencio Banico, a passenger on the bus, corroborated Dayuday's account, stating that the petitioner did not assist the victims after the accident.
Victims' Background and Claims for Damages
- Reynard So: Aged 30, engaged in copra trading and sugar cane planting, claimed to earn approximately P80,000 monthly. His father testified to spending P87,200 on funeral expenses and sought P30,000 for attorney's fees.
- Nilo Castro: Aged 26, worked as a welder in Manila with a monthly income of P8,000. His mother testified to spending P30,000 on funeral expenses.
Defense's Arguments
- The defense called several witnesses, including police officers and the petitioner, who argued that the motorcycle was at fault for swerving into the bus's lane.
- The petitioner claimed he attempted to help the victims after the accident.
Trial Court's Decision
- The trial court found the peti