Case Summary (G.R. No. L-22533)
Lower Court Proceedings
Following the collision, the Ramoses initiated legal action against PEPSI-COLA and Bonifacio in the Court of First Instance of Manila on June 30, 1958. After a thorough trial, the court issued a ruling on April 15, 1961, determining that Andres Bonifacio was negligent while driving the tractor-truck. The court found that PEPSI-COLA did not adequately demonstrate that it exercised the diligence expected of a good father of a family in employing Bonifacio. Consequently, both Bonifacio and PEPSI-COLA were ordered to pay the Ramoses a total of P2,638.50 in actual damages, alongside P2,000.00 in moral damages, P2,000.00 in exemplary damages, and P1,000.00 in attorney’s fees.
Appeal to the Court of Appeals
Dissatisfied with the trial court's judgment, PEPSI-COLA and Bonifacio appealed to the Court of Appeals. On January 15, 1964, the appellate court affirmed the trial court's finding of Bonifacio's negligence but reversed the liability on the part of PEPSI-COLA. The Court of Appeals maintained that the evidence produced by PEPSI-COLA sufficiently demonstrated its exercise of due diligence in the hiring and supervision of Bonifacio.
Argument on Appeal
The Ramoses subsequently filed a petition for review to contest the Court of Appeals' decision. Their central argument centered around the assertion that PEPSI-COLA's evidence failed to satisfactorily establish due diligence in selecting Bonifacio as its driver. The Court of Appeals had referenced the testimony of Juan T. Anasco, the personnel manager of PEPSI-COLA, which detailed the rigorous hiring process undertaken for Bonifacio, including background checks, physical examinations, and successful completion of both theoretical and practical driving tests.
Evaluation of Credibility
In their appeal, the Ramoses challenged Anasco's credibility, asserting that he was biased due to his employment with PEPSI-COLA and therefore his testimony was inherently unreliable. The Supreme Court emphasized that such credibility assessments fall within the jurisdiction of the appellate court, which is respected in higher courts unless inconsistencies or manifest errors are evident. The Supreme Court reiterated the principle that the appeal should not revisit factual matters already settled by the Court of Appeals.
Legal Principles Applied
The Supreme Court referenced Article 2180 of the Civil Code, which outlines the liability of employers for damages caused by their
...continue readingCase Syllabus (G.R. No. L-22533)
Case Overview
- The case originated from a collision that occurred on May 10, 1958, involving the car of Placido Ramos, driven at the time by his son Augusto Ramos, and a tractor-truck and trailer owned by Pepsi-Cola Bottling Co. of the P.I., driven by Andres Bonifacio.
- Placido and Augusto Ramos filed a lawsuit against the defendants in the Court of First Instance of Manila on June 30, 1958, seeking damages for the collision.
Trial Court Decision
- On April 15, 1961, the trial court rendered a judgment finding Andres Bonifacio negligent.
- The court concluded that Pepsi-Cola failed to demonstrate that it exercised the due diligence of a good father of a family to prevent the accident.
- The defendants were ordered to pay the plaintiffs:
- P2,638.50 in actual damages
- P2,000.00 in moral damages
- P2,000.00 in exemplary damages
- P1,000.00 in attorney's fees, plus costs.
Court of Appeals Ruling
- The defendants appealed the trial court's decision.
- On January 15, 1964, the Court of Appeals affirmed the finding of negligence against Bonifacio but modified the judgment by absolving Pepsi-Cola from liability.
- The appellate court found that Pepsi-Cola had sufficiently proven due diligence in the selection of its driver, Bonifacio.
Argument of the Petitioners
- The petitioners (Ramos) contended that Pepsi-Cola's evidence did not adequately prove that it exercised due diligence in the selection of Bonifacio.
- They claimed that the testimony of