Title
Rebultan vs. Spouses Daganta
Case
G.R. No. 197908
Decision Date
Jul 4, 2018
A 1999 vehicular collision led to a fatality, with both drivers found negligent. The Supreme Court ruled both jointly liable, reinstating damages for the victim's heirs.
collision
passenger jeepney
death of passenger

Case Summary (G.R. No. 197908)

Factual Background

On May 3, 1999 at about 6:30 a.m., a Kia Ceres carrying Cecilio Rebultan, Sr. and driven by Jaime Lomotos collided with an Isuzu passenger jeepney driven by Willie Viloria along the National Highway in Barangay Mabanglit, Cabangan, Zambales. The Kia Ceres was proceeding northbound to Iba while the jeepney was traveling southbound to Cabangan. The impact seriously injured Rebultan, Sr. and Lomotos, and later caused the death of Rebultan, Sr., who was sixty years old at the time.

Trial Court Proceedings

The heirs of Rebultan, Sr. filed a complaint for damages against Viloria and the spouses Daganta as jeepney owners, claiming loss of life, loss of earning capacity, actual and moral damages, and attorney’s fees. Respondents denied liability, alleged the Kia Ceres driver’s negligence, and counterclaimed for repair costs, lost income, and fees. The spouses Daganta filed a third-party complaint against Lomotos, who denied liability. After trial, the RTC found Viloria negligent and the spouses Daganta vicariously liable, rendering judgment on July 24, 2008 ordering payment of P71,857.15 as actual damages, P50,000 as moral damages, P1,552,731.72 as loss of earning capacity, and P50,000 as attorney’s fees, and dismissing the third‑party complaint against Lomotos.

Court of Appeals’ Decision

Respondents appealed only the finding of negligence against Viloria. The CA reversed and set aside the RTC decision and dismissed the complaint. The CA concluded that Lomotos, not Viloria, was negligent. It relied on Section 42(a) and (b) of R.A. No. 4136, concluded that the jeepney had the right of way as a vehicle on the right or as one already turned left, and applied Article 2185 to presume negligence from violation of traffic regulations. The CA noted that it could not reverse the RTC’s dismissal of the third‑party complaint because respondents had not appealed that dismissal.

Petitioners’ Contentions on Review

Petitioners argued that the CA erred in absolving Viloria of negligence. They pointed to conflicting testimony by Viloria, testimony by Lomotos that Viloria was racing a mini‑bus and abruptly swerved left, and Traffic Accident Report No. 99002. They challenged the evidentiary weight of the sketch and post‑collision photographs relied upon by respondents. Petitioners maintained that the evidence showed Lomotos driving in his lane while Viloria overtook a larger vehicle and made an imprudent left turn to avoid collision.

Issue Presented

The sole issue before the Supreme Court was whether Viloria was negligent in operating the jeepney at the time of the collision, and whether the CA’s factual finding absolving him of negligence warranted reversal under Rule 45.

Supreme Court’s Disposition

The Supreme Court granted the petition. It reversed and set aside the CA Decision dated April 26, 2011 and Resolution dated July 20, 2011 in CA‑G.R. CV No. 92218, and reinstated the RTC Decision dated July 24, 2008 in Civil Case No. RTC‑1668‑I. No costs were awarded.

Reasoning and Legal Basis

The Court reiterated that under a petition for review on certiorari under Rule 45, review is generally limited to questions of law, and findings of fact of lower courts are accorded respect. The Court noted, however, recognized exceptions permitting review when the CA’s findings contradict the trial court’s, rest on manifestly mistaken inferences, or are otherwise flawed. The Court found such an exception because the RTC and the CA reached contradictory factual conclusions and because the CA made a manifestly mistaken inference in construing the right‑of‑way rules. The CA had misapplied Caminos, Jr. v. People by treating the left‑turning jeepney as having the right of way. The Supreme Court explained that Caminos, Jr. holds that a vehicle making a left turn must yield to an oncoming vehicle on its right where the vehicles approach the intersection at approximately the same time; that the right of way is not absolute; and that a favored driver must still exercise due care and may forfeit the right of way by unlawful speed. The CA’s conclusion that the jeepney already occupied the intersection and therefore had the favored status was unsupported by the record.

Findings on Negligence of Both Drivers

The Court affirmed the CA’s finding that Lomotos was negligent for overspeeding. It relied on Traffic Accident Report No. 99002, which listed “overspeeding” and “driving too fast,” and on testimonial corroboration including Ronald Vivero’s account of a loud screech indicating high speed. The Court nevertheless held that Viloria’s negligence also contributed to the collision. It cited Section 48 of R.A. No. 4136 prohibiting reckless driving and noted Viloria’s admissions that he did not look to his right and continuously drove without yielding, his overtaking of a mini‑bus near the intersection as shown in the traffic report, and the RTC’s factual finding that Viloria failed to exercise prudence in making a left turn. The Court concluded that Viloria’s failure to approach and execute the left turn with due regard for others amounted to negligence.

Liability, Damages, and Third‑Party Complai

...continue reading

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.

About Privacy Terms