G.R. No. L-47772 - Tugade vs. Court of Appeals

Accident occurred on January 4, 1972 (Ayala Avenue at Makati Avenue, Makati, Rizal).
Lower court convicted Tugade of Reckless Imprudence Resulting in Damage to Property and imposed a fine of P1,000, subsidiary imprisonment if insolvent, and an award of actual damages of P778.10 to Sta. Ines Mining Corporation (with costs).
Court of Appeals reviewed the record and affirmed the trial court’s judgment.
Petition for review to the Supreme Court followed; the Supreme Court affirmed the Court of Appeals’ decision.

Statutory reference invoked in the judgments: Article 39 of the Revised Penal Code (provision authorizing subsidiary imprisonment in case of insolvency for monetary penalties).
Controlling precedents cited by the Supreme Court: La Mallorca and Pampanga Bus Co. v. De Jesus (L-21486, May 14, 1966, 17 SCRA 23), Lasam v. Smith (45 Phil. 657, 1924), Son v. Cebu Autobus Co. (94 Phil. 892, 1954), Necesito v. Paras (104 Phil. 75, 1958), and Barrera v. Barrera (L-31589, July 31, 1970, 34 SCRA 98).
Constitutional context: The decision was rendered in 1978 and thus arises under the constitutional and judicial framework operative at that time (the applicable constitution for that period is the 1973 Constitution).

While stopped to await a left-turn signal at the Ayala Avenue–Makati Avenue intersection, the Holden car driven by Rayandayan was bumped from behind by Tugade’s taxi, causing property damage.
Tugade admitted the collision and acknowledged that his taxi’s brakes malfunctioned; he contended that the mechanical defect could not be traced to his culpable conduct and thus should exculpate him.
Repair cost for the Holden car was P778.10.

The trial court found Tugade guilty beyond reasonable doubt of reckless imprudence resulting in damage to property, imposed a fine of P1,000 (with subsidiary imprisonment in case of insolvency under Article 39 RPC), ordered indemnity of P778.10, and imposed costs.
On appeal, the Court of Appeals reviewed the record, agreed with the trial court’s findings and reasoning (including the treatment of the brake malfunction), and affirmed the conviction and penalties in toto.

Central legal question: Whether a vehicular accident caused by a mechanical defect (faulty brakes) constitutes a caso fortuito (fortuitous event) that would absolve the driver from criminal liability for reckless imprudence, or whether such mechanical failure may be attributed to the driver and therefore support criminal responsibility.

The Supreme Court declined to overturn the Court of Appeals’ application of precedent. The Court emphasized that the La Mallorca decision (and related precedents) squarely addressed the legal issue and held that mechanical defects or similar circumstances resulting from defects in the automobile are not, per se, caso fortuito that absolve the driver.
The Court rejected counsel’s contention that La Mallorca and related pronouncements were merely obiter dicta. The opinion explained that La Mallorca expressly and directly addressed the question of whether a tire blow-out (analogous to a mechanical defect) constitutes a fortuitous event and held that it does not. Thus, La Mallorca was binding precedent on the specific legal point.
The Court noted that the reference in La Mallorca to Court of Appeals cases did not weaken its authority; the Supreme Court’s pronouncements are binding and authoritative on lower courts. The Court reiterated the principle that the highest judicial tribunal must speak with one voice on points of law to assure stability and avoid confusion, citing Barrera v. Barrera and other authorities to emphasize the obligation of lower tribunals to follow Supreme Court decisions.
The Court also traced the doctrine to earlier Supreme Court decisions, such as Lasam v. Smith (1924), which established that a caso fortuito requires an extraordinary circumstance i

Reported at 174 Phil. 475, Second Division, G.R. No. L-47772, decided August 31, 1978.
Opinion of the Supreme Court delivered by Justice Fernando.
Decision of the respondent Court of Appeals (ponente: Justice Juliano Agrava) was the subject of the petition.

Petitioner Inocencio Tugade sought review of a decision of the Court of Appeals affirming his conviction by the lower court.
The petition to this Court argued that the Court of Appeals relied on a Supreme Court case (La Mallorca and Pampanga Bus Co. v. De Jesus) instead of other Court of Appeals rulings counsel considered controlling.
The Supreme Court granted due course to the petition primarily to clarify the state of the law, but ultimately found no reversible error in the Court of Appeals' decision.

On January 4, 1972, at about 9:15 a.m., Rodolfo Rayandayan was driving a Holden Kingswood car (plate No. 52-19V, L-Rizal ’71) owned by the Sta. Ines Mining Corp., assigned to its manager, on Ayala Avenue in Makati, Rizal, going northwards.
At the intersection of Ayala Avenue and Makati Avenue Rayandayan intended to turn left and stopped to wait for the left-turn signal; a jeep ahead of him was also stopped.
While stopped, the Holden car was bumped from behind by Blue Car Taxi (plate No. 55-71R, TX-QC ’71) driven by petitioner Inocencio Tugade, causing damage to the Holden car; repairs cost P778.10.
Tugade was charged with Reckless Imprudence Resulting in Damage to Property.
Tugade pleaded not guilty but admitted the collision was caused by faulty brakes of his taxicab and presented a handwritten statement to that effect; he sought to exculpate himself by claiming the brake malfunction was a mechanical defect beyond his control.
The trial court found Tugade guilty beyond reasonable doubt, sentenced him to a fine of P1,000 with subsidiary imprisonment in case of insolvency (Article 39, Revised Penal Code, as amended), ordered indemnification to Sta. Ines Mining Corporation in the amount of P778.10 as actual damages, and imposed costs.
Tugade appealed to the Court of Appeals; that court affirmed the trial court’s judgment in toto on December 15, 1977.
Tugade then filed the present petition for review to the Supreme Court.

Whether the Court of Appeals erred in applying the pronouncement of this Court in La Mallorca and Pampanga Bus Co. v. De Jesus (L-21486, May 14, 1966, 17 SCRA 23) — particularly whether that pronouncement was merely obiter dictum and therefore not controlling — such that petitioner Tugade should be acquitted because the collision was caused by a mechanical defect (faulty brakes) that could not, even with due diligence, have been prevented by him.

The petition is without merit; the decision of the Court of Appeals dated December 15, 1977 is affirmed.
No costs are awarded.
The Supreme Court observed that while the petition was unpersuasive on its merits, the Court nevertheless granted due course to clarify the law.
The Court noted that at most the fine imposed might be susceptible to reduction, but the conviction and indemnity were sustained.

The Supreme Court held that the Court of Appeals correctly applied the doctrine announced in La Mallorca and Pampanga Bus Co. v. De Jesus; that ruling was not obiter dictum but a binding pronouncement of this Court on the point raised.
The opinion in La Mallorca (authored by then-Justice Makalintal) specifically addressed and rejected the contention that a tire blow-out was a fortuitous event giving rise to no liability for negligence, stating that the cited Court of Appeals rulings (Rodriguez v. Red Line Transportation Co. and People v. Palapal) were not binding and were based on different considerations.
The Supreme Court emphasized