Title
Philippine National Railways vs. Court of Appeals
Case
G.R. No. 157658
Decision Date
Oct 15, 2007
A pedestrian was struck and killed by a PNR train at an unsafe, poorly marked crossing. The Supreme Court ruled PNR negligent for inadequate safety measures, affirming liability for damages.

Case Summary (G.R. No. 157658)

Key Dates and Procedural Posture

Accident occurred April 27, 1992. Complaint filed July 22, 1992 before the Regional Trial Court (RTC) of Manila, Branch 28, docketed Civil Case No. 92-61987. RTC rendered judgment for petitioners on August 22, 1996. The Court of Appeals (CA) reversed and awarded damages to respondents. Petition for review on certiorari under Rule 45 to the Supreme Court followed; the Supreme Court denied the petition and affirmed the CA decision.

Applicable Law and Legal Foundation

Primary tort provision: Article 2176, New Civil Code (quasi-delict). Employer liability by operation of law: Article 2180, New Civil Code (responsibility of owners/managers for acts of employees unless due diligence is shown). Statutory reference for vehicular duty at crossings: Section 42(d), R.A. No. 4136 (Land Transportation and Traffic Code). The decision was rendered under the 1987 Constitution as applicable to cases decided from 1990 onward.

Factual Findings Established in the Record

Amores stopped briefly before crossing the tracks, proceeded, and was struck by PNR locomotive T-517 at the Kahilum II intersection. At the time of impact there was no crossing bar, no posted flagman, and no signaling device in working order; the only sign was a deteriorated “STOP, LOOK and LISTEN” sign with the “LISTEN” word missing and “LOOK” bent. No whistle or horn from the locomotive was heard prior to impact. The automobile was dragged approximately ten meters beyond the center of the crossing; Amores died from the collision.

Parties’ Claims and Defenses Presented to the Courts

Respondents alleged PNR negligence in failing to provide adequate warnings (no semaphore, crossing bar, flagman, or working sign) and charged driver Borja with negligent operation (failure to sound horn and late braking). Petitioners denied negligence, asserting the train was railroad-worthy, the speedometer defect did not affect operation, and Amores’s own negligence or misjudgment in attempting to beat the train was the proximate cause. PNR also invoked the statutory duty of motorists under Section 42(d), R.A. No. 4136, to stop and look before traversing crossings.

RTC Decision and Rationale

The RTC found for petitioners, concluding that Amores’s misjudgment and reckless attempt to cross despite seeing or hearing the approaching train constituted the proximate cause of the collision. The complaint and counterclaim were dismissed and costs were apportioned.

CA Reversal and Rationale

The Court of Appeals reversed the RTC and held PNR and the estate of Borja jointly and severally liable. The CA’s essential findings were: (1) the crossing was in a densely populated area and thus required greater protective measures (semaphore, flagman or at least adequate signage); (2) the existing sign was defective and insufficient; (3) no flagman or whistle warned the public; and (4) Amores exercised reasonable care in crossing. The CA awarded P122,300.00 for damage to the car and P50,000.00 as moral damages, but denied claims for funeral expenses and support for lack of documentary proof.

Supreme Court Issue on Review

The controlling issue before the Supreme Court was whether the Court of Appeals erred in attributing negligence to PNR and Borja and whether the appellate court’s reversal of the RTC was an abuse of discretion or contrary to the record.

Supreme Court Analysis on Negligence of PNR and Driver

The Supreme Court affirmed the CA finding of negligence. It applied the general tort standard of Article 2176: negligence exists when one fails to observe the degree of care and vigilance circumstances demand. The Court emphasized fact-dependent calibration of required care and found that PNR failed to exercise the degree of care demanded by the circumstances: the train was running fast (as evidenced by distance dragged after braking), warnings were inadequate (no crossing bar, no flagman, defective signboard), and the locomotive did not warn (no whistle heard). The Court cited precedents establishing that railroad companies owe the public reasonable care at crossings and must maintain signaling devices in good condition; failure to do so indicates negligence.

Consideration of Motorist Duty under R.A. No. 4136 and Response to Petitioners’ Argument

Petitioners relied on Section 42(d) of R.A. No. 4136 to argue motorists bear a heavier responsibility to stop, look and listen and that the obligation to stop only applies where the crossing is designated and sign-posted as a “through street.” The Supreme Court acknowledged the duty of motorists to exercise sight and hearing at crossings but found that

...continue reading

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster—building context before diving into full texts.