Case Summary (G.R. No. L-26810)
Relevant Facts
On February 27, 1964, the plaintiffs left Barrio Sumilang, Pasig, for Pansol hot springs, Laguna. The Mercedes Benz was driven by Alberto Concepcion, who was proceeding at a cautious speed of 30 miles per hour due to slippery road conditions caused by rain. As they navigated an area with a parked cargo truck, a passenger bus driven by Sergio de Luna swerved into their lane, resulting in a collision that led to the death of Jovito Bonifacio Sr. and serious injuries to the other parties involved.
Legal Issue: Driver Negligence
The primary legal issue was identifying fault in the accident. The court found that the negligence of Sergio de Luna was the proximate cause of the collision. Despite the poor visibility and wet conditions, de Luna failed to exercise the necessary caution required in such circumstances, particularly since he was driving at a speed deemed excessive under the conditions. His admission of suddenly braking upon seeing the truck indicated a lack of attentiveness, as he only perceived the danger when he was dangerously close.
Defence Argument: Company Negligence
The B. L. T. Bus Company argued that it had exercised due diligence in hiring and supervising de Luna. Evidence presented included the training and examinations administered to its drivers, as well as adherence to safety protocols. However, the court found this defense insufficient when juxtaposed with evident lapses in both driver supervision and vehicle maintenance, which contributed to the driver’s inability to control the bus.
Employer Liability
Based on Articles 2180 and 2190 of the Civil Code, the employer can be held vicariously liable for the negligent acts of its employees committed in the course of employment, unless it can prove due diligence in the selection and supervision of its personnel. The court determined that the employer had not exercised such diligence, citing specific failures, including overdue maintenance of the bus and repeated tolerances of de Luna's infractions.
Damages Awarded
The trial court awarded damages, totaling P240,905.72 to the plaintiffs, accounting for the loss of life, medical expenses, and suffering endured by the victims. Damages included the actual expenses incurred by the family, compensatory damages based on lost income and future earnings of the deceased, moral damages, and additional exemplary damages served to deter similar misconduct.
Conclusion on Appeals
The appellants als
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Case Overview
- This case involves a direct appeal to the Supreme Court from the judgment of the Court of First Instance of Rizal, which found the defendants-appellants, B. L. T. Bus Co., Inc. and its driver Sergio de Luna, liable for damages resulting from a vehicular accident.
- The plaintiffs-appellees were awarded a total of P240,905.72 in damages, along with interest from the filing of the complaint.
- The civil case was filed separately from a criminal case against de Luna, who was convicted of homicide and multiple physical injuries through reckless imprudence.
Facts of the Case
- On February 27, 1964, Jovito Bonifacio, Sr., with family and a neighbor, traveled to the Pansol hot springs in Laguna in a 1962 Mercedes Benz driven by Alberto Concepcion.
- The accident occurred around 5:20 a.m., in dark and rainy conditions, when the Mercedes Benz collided with an oncoming LTB bus driven by Sergio de Luna, who was traveling at high speed.
- The bus swerved into the lane of the Mercedes Benz, causing a violent collision that resulted in the death of Jovito Bonifacio, Sr., and serious injuries to the other occupants of the Mercedes.
Issues Presented
- The case raised three primary issues:
- Determining the fault of the drivers of the colliding vehicles.
- Assessing the employer's liability for the acts of its employee.
- Evaluating the reasonableness of the damages awa