Title
R Transport Corp. vs. Pante
Case
G.R. No. 162104
Decision Date
Sep 15, 2009
A common carrier, R Transport Corp., held liable for damages after its bus driver's reckless driving caused injuries to passenger Eduardo Pante. Courts affirmed awards for actual, moral, exemplary damages, and attorney’s fees.
A

Case Summary (G.R. No. 162104)

Petitioner

R Transport Corporation is a common carrier operating a bus line between Cubao, Quezon City and Gapan, Nueva Ecija. It denied liability, asserting that it exercised the diligence of a good father in hiring and supervising employees and that the accident was a force majeure.

Respondent

Eduardo Pante purchased a bus ticket (No. 555401) for P48.00 and rode petitioner’s bus (Plate CVW-635, Body No. 94810). He alleged physical injuries caused by fast and reckless driving that resulted in the bus hitting a tree and a house.

Key Dates and Procedural Posture

Accident: January 27, 1995. Complaint filed: March 14, 1995 with RTC Gapan City, Branch 35 (Civil Case No. 1460). RTC decision: June 26, 2002 (finding petitioner liable and awarding damages). Court of Appeals decision: October 7, 2003 (affirmed RTC). CA resolution denying reconsideration: February 5, 2004. Petition for review under Rule 45 to the Supreme Court; Supreme Court decision affirming the CA on September 15, 2009. Governing constitution for the decision: 1987 Philippine Constitution.

Applicable Law and Governing Legal Standards

Primary substantive law applied: Civil Code provisions on common carriers — Articles 1733, 1755, 1756, 1759, and damages provisions (Arts. 2219, 2220, 2232). Procedural reference: Rule 45 for petition for review on certiorari. Constitutional baseline invoked by Court for procedural fairness: due process guarantees under the 1987 Constitution (as the decision post-dates 1990).

Factual Findings — Accident and Injuries

At about 3:00 a.m. on the date in question, the bus operated by petitioner struck a tree and a house in Baliuag, Bulacan. Respondent suffered a laceration to the frontal area and fracture of the right humerus. An unidentified petitioner employee brought respondent to Baliuag District Hospital, where Dr. Virginia C. Cabling issued a certification that respondent underwent operative treatment for the fractured humerus.

Medical Treatment and Economic Losses

Respondent’s hospital Statement of Account recorded P22,870.00 for operation and confinement. Additional medication expenses totaled P8,072.60. Respondent later underwent a second operation with additional medical and hospitalization expenses of P15,170.00. Petitioner provided initial assistance of P7,000.00 to respondent’s wife for a stainless steel instrument; respondent also lost employment for nearly a year due to disability.

Trial Conduct and Waiver of Evidence

The case experienced repeated postponements, several due to motions by petitioner, and lengthy delay over seven years. At trial petitioner was declared to have waived its right to cross-examine the respondent because of repeated unexplained absences of petitioner and counsel (cross-examination resets and eventual waiver). On June 19, 2002, petitioner was declared to have waived its right to present evidence for unexplained absence despite notice; the case was submitted for decision without petitioner’s evidence.

Due Process Contentions and Court’s Ruling

Petitioner contended that denial of opportunity to present evidence violated its right to due process. The Court held there was no denial of due process because petitioner had ample opportunity to be heard but repeatedly failed to attend and to present evidence; waiver was properly found. Citing Silverio, Sr. v. Court of Appeals and principles that an opportunity to be heard suffices, the Court concluded petitioner’s own conduct justified the waiver.

Liability of Common Carriers — Presumption and Legal Consequences

The Court applied Civil Code jurisprudence holding common carriers to extraordinary diligence (Arts. 1733 and 1755) and the presumption of fault in passenger death or injuries (Art. 1756). Article 1759 makes common carriers liable for death or injury caused by employees’ negligence irrespective of supervision diligence. Given the bus’s collision and respondent’s unrebutted testimony describing fast and reckless driving by the driver, the presumption of carrier negligence remained unrebutted; petitioner therefore bore liability.

Evidence and Admissibility Issues

Petitioner argued that the hospital Statement of Account was not the best evidence and that the medical certificate lacked probative value because the issuing physician was not presented. The Court rejected these objections: prior jurisprudence admitted hospital statements as evidence of hospital expenses (citing Jarco Marketing Corp.); the medical certificate was admissible and unobjected to by petitioner at trial. The Court found the documentary evidence sufficient to support the award of actual damages and medical expense findings.

Damages — Actual, Moral, Exemplary, and Attorney’s Fees

The RTC awarded P39,112.60 as actual damages (hospitalization and related expenses aggregated), P50,000.00 as moral

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