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CASE DIGEST Batangas Laguna Tayabas Bus Co. (BLTB Co.) vs CA, G.R. No.

L-33138-39, June 27, 1975 This is a case based on quasi-delict or culpa aquiliana filed against BLTB Co. and his driver for the vehicular accident which resulted to death and damage to properties. Facts of the Case: On the morning of February 18, 1963, Andres I. Ilagan drove the passenger bus owned by BLTB Co. along Manila South Super Highway on its way to Lemery, Batangas while Ricardo de los Reyes with his Chevrolet car left Calamba, Laguna with Eduardo de los Reyes, Jean Elizondo, Eufrocina Alcalde Cardema, and Ursula Bayan, and bound for Manila. In the ensuing event, both vehicles collided with each other. The tragic accident occurred when the bus driven by Ilagan overtook a big cargo truck. The bus took the left or the lane on which the car driven by de los Reyes was traveling. The latter being in the best position to see the fast approaching bus tried to swerve to the right to avoid the bus but was too late and hit in the left front side up to the driver's door. Both de los Reyes and Elizondo were rushed to the Phil. General Hospital but were pronounced dead upon arrival at the hospital while the rest of the fatalities were brought to Manila Rail Road Hospital for treatment. Subsequently, a criminal case was filed against Ilagan for reckless imprudence and the injured parties sought for payment of their hospital bills and other expenses from the petitioners but the latter refuse, thus, two civil cases were filed in the Court of First Instance of Laguna for recovery of damages. The lower court decided in favor of the plaintiffs and award damages. The respondents not contented, appeal the decision to the Court of Appeals but was denied, thus this appeal by certiorari in the Supreme Court. Issue: Whether or not BLTB Co. and Andres I. Ilagan are liable for damages for the injury inflicted to the plaintiffs. Whether or not the doctrinal rule on Corpus vs Paje is applicable to the case. Ruling: Yes, BLTB Co. and Andres I. Ilagan are liable for damages and the case of Corpus vs Paje is not applicable to the case.

Under the law, "Whoever by act or omission causes damage to another, there being fault or negligence, is obliged to pay for the damage done. Such fault or negligence, if there is no pre-existing contractual relations between the parties, is called a quasi-delict. Further, the "Employers shall be liable for the damages caused by their employees xxx acting within the scope of their assigned tasks, even though the former are not engaged in any business or industry." In this case, undisputable facts were established by both the trial and appellate courts on the reckless and imprudent acts by the driver of the bus. Though BLTB Co and his driver-co-appellants, Ilagan asserted that they had exercise extraordinary diligence of a good father and the accident was fortuitous in character, and that the accident was due to the negligence of Ricardo de los Reyes were presumptive and unproven by the appellants. Further, appellants reliance on the case of Corpus vs Paje that "the criminal action against petitioner Ilagan must first be resolved by respondent Court of Appeals and, until final resolution thereon, it is premature to proceed in the two civil cases was came too late because it was never raised in the lower and appellate courts and the facts were dissimilar to the case, thus, not controlling said the Supreme Court. In fact, the liability of appellants was not predicated on criminal negligence but rather on being a quasi-delict or culpa aquiliana is an independent source of obligation between two persons not so formerly bound by any juridical tie, thus the awards for damages against appellants were proper and just. Accordingly, the lower court and court of appeals decision is affirmed by the Supreme Court.