Andamo vs.
Intermediate Appellate Court The nature of an action filed in court is determined by the facts alleged in the
A corporation is held civilly liable for damages caused by the construction of
waterpaths and contrivances within its land, resulting in inundation, erosion, and
endangerment of lives, as ruled by the Supreme Court in the case of Andamo v.
Intermediate Appellate Court.
Facts:
Petitioner spouses Emmanuel and Natividad Andamo own a parcel of land adjacent
to the land owned by respondent Missionaries of Our Lady of La Salette, Inc., a
religious corporation.
The respondent corporation constructed waterpaths, water conductors, and
contrivances within its land, including an artificial lake.
The construction allegedly caused inundation and erosion of the petitioners' land.
The construction also resulted in the drowning of a young man, damage to crops and
plants, destruction of fences, and endangerment of lives during rainy and stormy
seasons.
The petitioners filed a criminal case against the officers and directors of the
respondent corporation for destruction by means of injunction.
They also filed a civil case for damages with a prayer for a preliminary injunction
against the respondent corporation.
Issue:
Can a corporation be held civilly liable for damages caused by the construction of
waterpaths and contrivances within its land, resulting in inundation and erosion of
an adjacent land, endangering lives and causing destruction of crops and plants?
Ruling:
The Supreme Court ruled in favor of the petitioners and reversed the decision of the
Intermediate Appellate Court.
The trial court was ordered to reinstate the civil case and proceed with the hearing.
The Court held that the civil action is entirely independent of the related criminal
case and can proceed based on quasi-delicts under Articles 2176 and 2177 of the
Civil Code.
Ratio:
complaint as constituting the cause of action.
The purpose of an action and the law to govern it, including the period of
prescription, is determined by the complaint itself, its allegations, and prayer for
relief.
The complaint sufficiently alleged that the respondent corporation's construction of
waterpaths and contrivances caused damage to the petitioners' land, which
constitutes fault or negligence and can be the basis for the recovery of damages
under quasi-delicts.
A civil action based on quasi-delicts is entirely independent of the related criminal
case.
Even if the tortfeasor is charged criminally, the offended party is not allowed to
recover damages on both scores.
Quasi-delicts are distinct from criminal negligence, as shown in Article 2177 of the
Civil Code.
Responsibility for fault or negligence under Article 2176 is entirely separate and
distinct from the civil liability arising from negligence under the Revised Penal Code.
The use of one's property is not without limitations.
Article 431 of the Civil Code provides that every owner must so use his property as
not to injure the rights of others.
The construction of waterpaths and contrivances by the respondent corporation
caused damage to the adjacent land, which is a violation of the duty to use one's
property without causing harm to others.
The respondent corporation can be held civilly liable for the damages caused by the
construction of waterpaths and contrivances within its land, based on the principles
of quasi-delicts under Articles 2176 and 2177 of the Civil Code.
Elcano vs. Hill
The case involves a civil action for damages filed by the parents of a deceased child
against a minor and his father, where the court ruled that the minor's acquittal in
the criminal case does not bar the civil action, and that the father is still liable
despite the minor's emancipation by marriage.
Facts:
The case involves a civil action for damages filed by the parents of a deceased child
against a minor and his father.
The minor, Reginald Hill, was acquitted in a criminal case for the killing of the
plaintiffs' son, Agapito Elcano, on the ground of lack of intent to kill coupled with
mistake.
The plaintiffs argue that the minor's acquittal does not bar the civil action and that
the father is still liable as the guardian.
The Court of First Instance of Quezon City initially denied the motion to dismiss filed
by the defendants, but upon reconsideration, ordered the dismissal of the case.
The plaintiffs appealed the decision, raising several issues.
Issue:
Is the present civil action for damages barred by the acquittal of Reginald in the
criminal case?
Can Article 2180 of the Civil Code be applied against Atty. Hill, the father, despite
Reginald's emancipation by marriage?
Ruling:
The present civil action for damages is not barred by Reginald's acquittal in the
criminal case.
Article 2180 of the Civil Code applies to Atty. Hill despite Reginald's emancipation by
marriage.
Ratio:
The court reiterated the principle established in Barredo v. Garcia that the same act
can result in both criminal liability and civil liability under the Penal Code and the
Civil Code.
The court held that the acquittal in the criminal case does not extinguish the liability
for quasi-delict, and a separate civil action can be filed against the offender.
Emancipation by marriage does not relieve the parents of their duty to supervise
their minor children and prevent them from causing damage to others.
Atty. Hill's liability has become subsidiary to that of his son, who is now of age.
Conclusion:
The court reversed the order of dismissal and ordered the trial court to proceed with
the case.
The liability of Atty. Hill as the father of the minor offender was upheld, but it
became subsidiary to the liability of his son.
Cinco vs. Canonoy
The Supreme Court grants a petition to proceed with an independent civil action for
damages to property, separate from a criminal case, emphasizing that liability in
quasi-delict is distinct from civil liability arising from negligence under the Penal
Code.
Facts:
Petitioner Porfirio P. Cinco filed a complaint in the City Court for recovery of
damages on account of a vehicular accident involving his car and a jeepney driven by
respondent Romeo Hilot and operated by respondents Valeriana Pepito and Carlos
Pepito.
A criminal case was filed against the driver.
At the pre-trial of the civil case, the respondents' counsel moved for the suspension
of the civil action pending determination of the criminal case, invoking Section 3(b),
Rule 111 of the Rules of Court.
The City Court granted the motion and ordered the suspension of the civil case.
Petitioner appealed to the Court of First Instance, alleging that the City Judge acted
with grave abuse of discretion in suspending the civil action for being contrary to law
and jurisprudence.
The Court of First Instance dismissed the petition.
Petitioner filed a petition for review on certiorari.
Issue:
Whether or not there can be an independent civil action for damages to property
during the pendency of the criminal action.
Ruling:
The Supreme Court held that an independent civil action for damages to property
can proceed separately from a criminal action.
The Court emphasized that liability in quasi-delict is entirely separate and distinct
from the civil liability arising from negligence under the Penal Code.
The civil action referred to in Section 3(b), Rule 111 of the Rules of Court, which
should be suspended after the criminal action has been instituted, is that arising
from the criminal offense and not the civil action based on quasi-delict.
The concept of quasi-delict includes not only injuries to persons but also damage to
property.
The civil case for damages to property can proceed independently of the criminal
case.
Ratio:
An action for damages based on Articles 2176 and 2180 of the New Civil Code is
quasi-delictual in character, which can be prosecuted independently of the criminal
action.
Liability in quasi-delict is entirely separate and distinct from the civil liability arising
from negligence under the Penal Code.
The civil action referred to in Section 3(b), Rule 111 of the Rules of Court, which
should be suspended after the criminal action has been instituted, is that arising
from the criminal offense and not the civil action based on quasi-delict.
The concept of quasi-delict includes not only injuries to persons but also damage to
property.
The civil case for damages to property can proceed independently of the criminal
case.
Conclusion:
The Supreme Court granted the petition and ordered the City Court to proceed with
the hearing of the civil case.
Garcia vs. Florido
A civil action for damages filed by petitioners who sustained injuries in a car collision
is deemed not premature and should proceed to trial, as the essential elements for a
quasi-delictual action were present and the filing of the civil action effectively
abandoned their right to press recovery for damages in the criminal case.
Facts:
German C. Garcia, Luminosa L. Garcia, and Ester Francisco filed a civil action for
damages against Marcelino Inesin, Ricardo Vayson, Mactan Transit Co., Inc., and
Pedro Tumala.
The petitioners hired a PU car owned and operated by Inesin and driven by Vayson
for a roundtrip from Oroquieta City to Zamboanga City.
While on the national highway, the PU car collided with an oncoming passenger bus
owned and operated by Mactan Transit Co., Inc. and driven by Tumala.
The collision resulted in injuries to the petitioners.
Issue:
Is the civil action for damages filed by the petitioners premature due to the
pendency of a criminal case against Tumala?
Ruling:
The civil action for damages filed by the petitioners is not premature and should
proceed to trial.
The dismissal of the complaint by the lower court was reversed.
Ratio:
The essential elements for a quasi-delictual action under Articles 2176-2194 of the
New Civil Code are present in the case.
The negligent act of the drivers, the resulting injuries to the petitioners, and the
absence of pre-existing contractual relations between the parties establish the basis
for a civil action for damages.
The fact that the complaint alleged a violation of traffic rules does not change the
nature of the action, as it is still based on culpa aquiliana.
The same negligent act can give rise to both a civil liability arising from a crime and
an action for quasi-delict.
The filing of the civil action by the petitioners effectively abandoned their right to
press recovery for damages in the criminal case, and they have chosen to pursue
their claim in the civil case.
The reservation requirement under Rule 111 of the Rules of Court is not applicable
in this case, as the civil action is based on quasi-delict and not on the civil liability
imposed by the Revised Penal Code.
Therefore, the dismissal of the complaint by the lower court was unjustified, and the
case should proceed to trial.
Supreme Transportation Liner, Inc. vs. San Andres
The Supreme Court ruled in favor of the petitioners in a civil action for damages,
allowing their counterclaim and clarifying that the reservation of the civil action
does not apply to independent civil actions under certain articles of the Civil Code.
Facts:
Respondent Antonio San Andres filed a civil action for damages against petitioners
Supreme Transportation Liner, Inc. and Felix Q. Ruz.
The incident occurred on November 5, 2002, when a bus owned by San Andres
sideswiped a Toyota Revo and then collided head-on with a bus owned by Supreme
Transportation Liner.
All vehicles involved were damaged.
San Andres filed a complaint for damages, alleging actual damage to his bus and
unrealized profits.
The petitioners argued that the proximate cause of the accident was the reckless
imprudence of San Andres' driver and sought damages for the damage to their bus
and medical expenses.
The Regional Trial Court (RTC) dismissed both San Andres' complaint and the
petitioners' counterclaim, ruling that the counterclaim was not allowed due to the
failure to reserve the right to file a separate civil action in the criminal case against
San Andres' driver.
Issue:
Whether the petitioners' counterclaim was correctly denied by the RTC.
Ruling:
The Supreme Court ruled in favor of the petitioners and allowed their counterclaim.
The Court held that the requirement for the reservation of the civil action does not
apply to independent civil actions under Articles 32, 33, 34, and 2176 of the Civil
Code.
The Court clarified that the petitioners' cause of action was based on a quasi-delict,
and their counterclaim was an independent civil action.
The Court noted that the RTC erred in applying the obsolete version of the Rules of
Court, which required the reservation of the right to file a separate civil action.
The Court emphasized that the revised rule no longer includes the independent civil
actions as requiring prior reservation.
However, the Court also stated that the petitioners must demonstrate that they will
not recover damages twice for the same incident, as double recovery is prohibited
under Article 2177 of the Civil Code.
The case was remanded to the RTC for further proceedings to allow the petitioners
to present evidence on their counterclaim, subject to the prohibition against double
recovery of damages.
Dulay vs. Court of Appeals
A widow and her children file a civil action for damages against a security company
and its employee after the employee shot and killed the widow's husband, alleging
negligence and vicarious liability, leading to the Supreme Court ruling that the
complaint stated a valid cause of action based on the employer's direct and
immediate liability under the Civil Code.
Facts:
Widow and her children filed a civil action for damages against a security company
and its employee.
The employee shot and killed the widow's husband.
Widow and her children alleged negligence and vicarious liability on the part of the
security company.
The case was initially dismissed by the Regional Trial Court.
The Court of Appeals affirmed the dismissal.
Issue:
Whether the complaint filed by the widow and her children states a valid cause of
action against the security company and its employee.
Ruling:
The complaint does state a valid cause of action based on the employer's direct and
immediate liability under Article 2180 of the Civil Code.
Ratio:
The court's ruling is based on the interpretation of Article 2176 of the Civil Code,
which covers not only acts of negligence but also acts that are intentional and
voluntary.
A separate civil action can be filed against the offender in a criminal act, whether or
not the offender is prosecuted or found guilty or acquitted.
The liability of the employer under Article 2180 is direct and immediate, and is not
conditioned upon prior recourse against the negligent employee or a showing of the
employee's insolvency.
Sufficiency of the Complaint:
The allegations in the complaint are sufficient to support a cause of action.
The complaint alleged an actionable breach on the part of the employee and the
employer.
The specific details of the negligence and vicarious liability can be better resolved
after trial on the merits.
Conclusion:
The Supreme Court reversed the dismissal of the civil action and remanded the case
to the Regional Trial Court for trial on the merits.
The complaint states a valid cause of action and the widow and her children should
be allowed to present evidence of their injury.
R Transport Corp. vs. Yu
R Transport Corporation is held primarily and solidarily liable for damages caused by
the negligence of their employee, who hit and ran over a pedestrian resulting in her
death, despite not being the registered owner of the vehicle involved.
OutlineParagraph
Facts:
R Transport Corporation filed a petition for review on certiorari to reverse a decision
holding them liable for damages caused by the negligence of their employee.
On December 12, 1993, a bus driven by Antonio P. Gimena, an employee of R
Transport Corporation, hit and ran over Loreta J. Yu, resulting in her death.
Luisito G. Yu, Loreta's husband, filed a complaint for damages against R Transport,
Gimena, and Metro Manila Transport Corporation (MMTC) for the death of his wife.
MMTC denied liability, stating that they were only the registered owner of the bus
and that R Transport was the actual owner and operator.
The Regional Trial Court (RTC) ruled in favor of Luisito Yu, holding R Transport
primarily and solidarily liable for damages.
The Court of Appeals (CA) affirmed the decision with modification, making Gimena
solidarily liable as well.
Issue:
Whether R Transport Corporation should be held liable for damages caused by the
negligence of its employee.
Ruling:
The Supreme Court affirmed the decision of the CA, holding R Transport primarily
and solidarily liable for damages.
R Transport failed to prove that it exercised the required diligence in the selection
and supervision of its driver, Gimena, who was found to be negligent in hitting and
running over the victim.
The fact that R Transport was not the registered owner of the bus does not exempt it
from liability.
The registered owner and the actual operator of a vehicle should be jointly and
severally liable for damages caused by the negligent operation of the vehicle.
Ratio:
The Court based its decision on the principle of negligence, stating that whether a
person is negligent or not is a question of fact.
The lower courts' findings on R Transport's negligence were supported by the
evidence presented.
R Transport failed to present any evidence of due diligence in the selection and
supervision of its employees.
The liability of the registered owner and the actual operator of a vehicle is joint and
several.
R Transport cannot escape liability for the negligence of its employee.
This principle is meant to protect the public and prevent unscrupulous transferees of
vehicles from evading liability for their own negligent acts.
Therefore, R Transport was held primarily and solidarily liable for damages caused by
the negligence of its employee.
Title
Tamayo vs. Aquino
In the case of Tamayo v. Aquino, the Philippine Court ruled that the registered owner
of a public service vehicle is liable for damages caused to passengers, even if the
vehicle had been sold or transferred to another person, and the transferee who
operated the vehicle at the time of the accident is also responsible and should
indemnify the registered owner for any damages.
Facts:
Jose G. Tamayo, the registered owner of a public service vehicle, was held liable for
damages caused to a passenger, Epifania Gonzales, who died in an accident while
riding aboard Tamayo's truck.
Tamayo claimed that he was not responsible for the accident as he had already sold
the truck to Silvestre Rayos before the accident occurred.
The Court found that Tamayo was still liable for the damages, even if the vehicle had
been sold or transferred to another person.
The Court also found that Rayos, the transferee who was operating the vehicle at the
time of the accident, was directly responsible for the accident and should be made
responsible to Tamayo for any damages that Tamayo may have to pay.
Issue:
Whether the registered owner of a public service vehicle is liable for damages
caused to passengers, even if the vehicle had been sold or transferred to another
person.
Ruling:
The registered owner of a public service vehicle is indeed responsible for damages
caused to passengers, even if the vehicle had been sold or transferred to another
person.
The responsibility of the registered owner is direct, and the transferee who operated
the vehicle at the time of the accident is also responsible and should indemnify the
registered owner for any damages that the latter may have to pay.
The remedy of the registered owner is through a third-party complaint against the
transferee.
Ratio:
The Court based its decision on the aim and policy of the law, which is to hold the
registered owner responsible for damages as an incident or consequence of
registration.
Allowing the registered owner to evade responsibility by proving the transfer or sale
of the vehicle would enable them to escape liability and transfer it to an indefinite
person or someone who cannot financially respond for the damages.
The protection the law aims to extend to victims of accidents on public highways
would become illusory if registered owners were given the opportunity to disprove
their ownership.
Therefore, the registered owner should not be allowed to prove the contrary to the
prejudice of the injured person.
The liability of the registered owner and the transferee is not that of joint tortfeasors
under Article 2194 of the Civil Code.
The registered owner's responsibility is direct, while the transferee is responsible to
the registered owner for any damages caused by their negligence.
The procedural means to enforce the liability of the transferee to the registered
owner is through a third-party complaint.
The Court clarified that the award of moral damages cannot be given in a suit for
breach of contract unless the defendant acted fraudulently or in bad faith.
In this case, there was no fraud or bad faith on the part of the registered owner or
the transferee, so the award of moral damages was not justified.
Spouses Mangaron vs. Hanna Via Design and Construction
The case involves a complaint for damages filed by spouses Emilio Mangaron, Jr. and
Erlinda Mangaron against Hanna Via Design and Construction for the negligent
driving of their company driver, resulting in serious physical injuries to the
petitioners, with the Court ruling that the registered owner of the vehicle is
primarily responsible for the consequences of its operation.
Facts:
Spouses Emilio Mangaron, Jr. and Erlinda Mangaron filed a complaint for damages
against Hanna Via Design and Construction.
The complaint was based on the negligent driving of the company driver, Crestino T.
Bosquit, which resulted in serious physical injuries to the petitioners.
The incident occurred when Bosquit bumped and dragged the petitioners' vehicle,
causing them to be confined in the hospital for a month.
The complaint invoked the respondent's vicarious liability for the actions of their
driver.
Issue:
Is the denial of the motion for demurrer to evidence proper in this case?
Ruling:
The denial of the motion for demurrer to evidence was tainted with grave abuse of
discretion.
The Regional Trial Court (RTC) has jurisdiction over the case as it involves a civil
complaint for damages.
The Court reversed the ruling of the RTC in denying the demurrer to evidence.
The Court applied the registered owner rule and held that the case should have
been dismissed.
Ratio:
The purpose of motor vehicle registration is to identify the owner so that
responsibility for any accidents or injuries caused by the vehicle can be fixed on a
definite individual.
The registered owner rule holds that the registered owner of a motor vehicle is
primarily responsible for the consequences of its operation, regardless of who the
actual owner might be.
In this case, the registered owner of the vehicle was Power Supply, not the
respondent.
Therefore, the Court held that the case should have been dismissed.
The application of the registered owner rule does not shield the real owner from
liability.
The registered owner can seek indemnification from the actual employer of the
negligent driver through a cross-claim.
This upholds the rights of the parties involved while championing the public policy
behind the registered owner rule.
Vda. de Bataclan vs. Medina
A bus accident leads to the death of passengers, and the court holds the driver and
carrier liable for negligence in failing to prevent the subsequent fire that caused the
fatalities.
Facts:
On September 13, 1952, a bus owned by Mariano Medina and operated by his
company, Medina Transportation, was traveling from Amadeo, Cavite to Pasay City.
The bus had approximately eighteen passengers, including Juan Bataclan, Felipe
Lara, a passenger known as Visaya, and Natalia Villanueva.
At around 2:00 am, while the bus was in Imus, Cavite, one of the front tires burst,
causing the bus to zig-zag and eventually overturn into a canal.
Some passengers managed to escape, but Bataclan, Lara, Visaya, and Villanueva
were trapped inside.
Calls for help were made, and a group of men arrived with a lighted torch made of
bamboo.
However, when they approached the overturned bus, a fire broke out and consumed
the bus, resulting in the death of Bataclan and the other trapped passengers.
Issue:
The main issue in the case is to determine the proximate cause of Bataclan's death
and the liability of Mariano Medina and his company for the incident.
Ruling:
The court ruled in favor of the plaintiffs and affirmed the decision of the trial court.
The court held that the proximate cause of Bataclan's death was the overturning of
the bus, which was due to the negligence of the driver and the carrier.
The court also found that the burning of the bus could be attributed to the
negligence of the carrier, as the driver and conductor should have known that
gasoline could leak from the overturned bus and should have warned the rescuers
not to bring a lighted torch near it.
The court applied the provisions of the Civil Code, particularly Articles 1733, 1759,
and 1763, which hold common carriers liable for the death or injuries of passengers
caused by the negligence of their employees.
Ratio:
The court defined proximate cause as the cause that produces the injury in a natural
and continuous sequence, without any efficient intervening cause.
In this case, the overturning of the bus was the proximate cause of Bataclan's death
because it led to the leaking of gasoline and the subsequent arrival of rescuers with
a lighted torch.
The court also emphasized the negligence of the carrier, through its driver and
conductor, in failing to warn the rescuers about the potential danger of bringing a
lighted torch near the bus.
The court applied the provisions of the Civil Code that impose a high standard of
care on common carriers and hold them liable for the negligence of their employees.
The court awarded compensatory, moral, and other damages to the plaintiffs,
increased the amount of damages awarded by the trial court, and ordered the
prosecution of the negligent driver.
Regala vs. Carin
A dispute between neighbors arises when one seeks permission to construct a
second floor but secretly plans to build a terrace atop the dividing wall, leading to a
lawsuit for damages, with the Supreme Court ruling that while the lack of a building
permit renders the petitioner liable for administrative sanctions, he is not liable for
damages, but must pay nominal damages to vindicate the respondent's right to
peaceful enjoyment of his property.
Facts:
Dispute between neighbors, Rodolfo N. Regala (petitioner) and Federico P. Carin
(respondent)
Petitioner sought permission from respondent to bore a hole through a shared
perimeter wall to construct a second floor
Petitioner's true intention was to build a second floor with a terrace atop the
dividing wall
During construction, respondent and his wife suffered from dust and dirt falling on
their property
Respondent filed complaint with Office of the City Engineer and Building Official for
various violations by petitioner
Respondent also filed complaint for damages against petitioner before RTC of Las
Piñas City
Issue:
Whether petitioner is liable for damages caused by construction work
If liable, the extent of damages to be awarded
Ruling:
RTC ruled in favor of respondent and awarded moral and exemplary damages, as
well as attorney's fees
Court of Appeals affirmed decision but reduced amount of damages awarded
Supreme Court partly granted petitioner's appeal and vacated decision of Court of
Appeals
Supreme Court ordered petitioner to pay respondent nominal damages in the
amount of P25,000
Ratio:
Petitioner was engaged in lawful exercise of property rights to introduce renovations
to his house
Lack of building permit rendered petitioner liable to administrative sanctions, but
not liable for damages
Petitioner and his witnesses took measures to prevent or minimize damage to
respondent's property
Measures included installing GI sheet strainers and cleaning area after work
No evidence to establish that damage inflicted upon respondent's property was
malicious or willful
Malicious or willful damage necessary for award of moral damages
Respondent's right to peaceful enjoyment of property inconvenienced, thus
awarded nominal damages to vindicate violated right
Tison vs. Spouses Pomasin
A dispute over a vehicular accident arises as conflicting testimonies are presented,
leading to a legal battle to determine who was at fault and negligent in causing the
accident.
Facts:
Vehicular accident occurred on August 12, 1994, along Maharlika Highway in
Barangay Agos, Polangui, Albay.
Accident involved a tractor-trailer driven by Claudio Jabon and a jitney driven by
Laarni Pomasin.
Parties involved were Gregorio Pomasin, Laarni's father, who was a passenger in the
jitney, and several other individuals who were either injured or killed in the accident.
Conflicting versions of the incident were presented by the parties.
Gregorio claimed that the tractor-trailer encroached on the jitney's lane and caused
the collision.
Jabon claimed that the jitney fell off the shoulder of the road and collided with the
tractor-trailer.
Issue:
Who was at fault or negligent in causing the vehicular accident?
Ruling:
Trial court ruled in favor of the defendants, dismissing the complaint for damages.
Trial court found that the negligence of Laarni, the jitney driver, was the proximate
cause of the accident.
Trial court considered Jabon's testimony more convincing and reliable than
Gregorio's, as Jabon had a better opportunity to observe the incident as the driver.
Trial court upheld the Affidavit of Desistance executed by Cynthia Pomasin, one of
Gregorio's daughters, as having been executed with the tacit consent of the
respondents.
Court of Appeals disagreed with the trial court's ruling and held that Jabon's reckless
driving caused the accident.
Court of Appeals relied heavily on Gregorio's testimony that the tractor-trailer was
driving too fast and encroached on the jitney's lane.
Court of Appeals disregarded the Affidavit of Desistance executed by Cynthia, stating
that she had no written power of attorney from the respondents and was confused
when she signed the affidavit.
Supreme Court reversed the decision of the Court of Appeals and upheld the ruling
of the trial court.
Supreme Court found that the trial court's conclusion that Laarni's negligence
caused the accident was more credible.
Supreme Court considered the relative positions of a driver and a passenger in a
vehicle and concluded that the driver's attention to the road is keener than that of a
mere passenger.
Supreme Court found that there was no showing that Jabon was negligent and that
there was no causal connection between the restrictions on Jabon's driver's license
and the accident.
Supreme Court dismissed the complaint for damages for lack of merit.
Ratio:
Supreme Court's decision was based on the principle that trial courts have the
unique opportunity to observe the witnesses first hand and assess their credibility.
Supreme Court gave weight to the trial court's finding that Laarni's negligence was
the proximate cause of the accident, considering Jabon's testimony as the driver
more reliable than Gregorio's as a mere passenger.
Supreme Court emphasized the need to establish a causal connection between the
violation of a traffic regulation and the injury sustained, and found that no such
connection was established in this case.
Supreme Court considered the Affidavit of Desistance as having no persuasive value,
as Cynthia was not armed with a special power of attorney to enter into a
settlement with the defendants.
Sabido vs. Custodio
Two trucks collide in a road curve, resulting in the death of a passenger who was
hanging on the side of one of the trucks; the Supreme Court holds both truck drivers
and the bus company jointly and severally liable for damages due to their
negligence.
Facts:
The incident occurred in Barrio Halang, Municipality of Lumban, Province of Laguna.
Two trucks, one driven by Nicasio Mudales and owned by Laguna-Tayabas Bus
Company, and the other driven by Aser Lagunda and owned by Prospero Sabido,
met each other in a road curve.
Agripino Custodio, a passenger of the bus, was hanging on the left side of the truck
and was sideswiped by Lagunda's truck.
Custodio was injured and died.
The Court of First Instance of Laguna and the Court of Appeals held the Laguna-
Tayabas Bus Co., Mudales, Sabido, and Lagunda jointly and severally liable for
damages.
Issue:
Whether the death of Agripino Custodio was due exclusively to the negligence of the
carrier and its driver.
Whether Sabido and Lagunda were guilty of negligence in connection with the
incident.
Whether Sabido and Lagunda can be held solidarily liable with the carrier and its
driver.
Whether the complaint against Sabido and Lagunda should be dismissed.
Ruling:
The Supreme Court affirmed the decision of the Court of Appeals, holding Sabido,
Lagunda, the Laguna-Tayabas Bus Co., and Mudales jointly and severally liable for
damages.
Ratio:
The carrier and its driver were found negligent for allowing Custodio to ride on the
running board of the bus, which violated the contract of carriage.
Sabido and Lagunda were found negligent for driving their truck at a great speed
and not exercising prudence to avoid the accident.
The negligence of both parties was the proximate cause of Custodio's death.
When the negligence of multiple parties contributes to a single injury and it is
impossible to determine the proportion of each contribution, each party is
responsible for the entire injury.
Therefore, Sabido, Lagunda, the Laguna-Tayabas Bus Co., and Mudales were held
jointly and severally liable for damages.
St. Mary's Academy vs. Carpitanos
St. Mary's Academy is held partially liable for the death of a student during a school
activity due to their failure to ensure safety, resulting in a court order to pay civil
damages to the parents.
Facts:
Sherwin Carpitanos, a student of St. Mary's Academy, died in a car accident caused
by a mechanical defect in a vehicle owned by Vivencio Villanueva and driven by
James Daniel II, a minor.
Sherwin's parents filed a lawsuit against St. Mary's Academy and the other
respondents for damages.
The trial court ruled in favor of Sherwin's parents, ordering St. Mary's Academy to
pay civil indemnity, actual and moral damages, and attorney's fees.
The court also declared Daniel subsidiarily liable, while Villanueva was absolved
from any liability.
On appeal, the Court of Appeals affirmed the decision of the trial court, holding St.
Mary's Academy liable for damages.
St. Mary's Academy appealed to the Supreme Court.
Issue:
Can St. Mary's Academy be held liable for the death of Sherwin Carpitanos?
Ruling:
The Supreme Court ruled in favor of St. Mary's Academy, reversing the decision of
the Court of Appeals.
The court held that for St. Mary's Academy to be liable, there must be a finding that
their negligence was the proximate cause of the accident.
However, there was no evidence that St. Mary's Academy allowed the minor to drive
the vehicle or that their negligence was the proximate cause of the accident.
The court also noted that the immediate cause of the accident was the detachment
of the steering wheel guide of the jeep, which was a mechanical defect and not
within the control of St. Mary's Academy.
Therefore, St. Mary's Academy cannot be held liable for the death of Sherwin
Carpitanos.
The court also deleted the award of moral damages and attorney's fees against St.
Mary's Academy.
Instead, the registered owner of the vehicle, Vivencio Villanueva, was held primarily
responsible for the damages caused by the accident.
Ratio:
The court emphasized that for St. Mary's Academy to be held liable, there must be a
finding that their negligence was the proximate cause of the accident.
In this case, there was no evidence that St. Mary's Academy allowed the minor to
drive the vehicle or that their negligence contributed to the accident.
The court also considered the immediate cause of the accident, which was the
detachment of the steering wheel guide of the jeep, a mechanical defect.
Since this mechanical defect was not within the control of St. Mary's Academy, they
cannot be held liable for the accident.
The court held that the registered owner of the vehicle, Vivencio Villanueva, should
be primarily responsible for the damages caused by the accident.
Therefore, the Supreme Court reversed the decision of the Court of Appeals and
absolved St. Mary's Academy from any liability.
Our Lady of Lourdes Hospital vs. Spouses Capanzana
A hospital is held liable for negligence after failing to provide timely medical care,
resulting in brain damage to a patient, and is ordered to pay damages to the
patient's family.
Facts:
Regina Capanzana, a 40-year-old nurse, was scheduled for her third caesarean
section (C-section) at Our Lady of Lourdes Hospital on January 2, 1998.
Regina went into active labor a week earlier and was brought to the hospital for an
emergency C-section.
After the operation, Regina complained of a headache, restlessness, and shortness
of breath.
Regina asked for oxygen but it was delayed.
Regina was eventually transferred to the Intensive Care Unit and later to Cardinal
Santos Hospital, where she was diagnosed with rheumatic heart disease mitral
stenosis and brain damage.
Regina was discharged in a vegetative state on January 19, 1998.
The spouses Capanzana filed a complaint for damages against the hospital, alleging
negligence on the part of the hospital and its nurses.
Issue:
Whether the hospital and its nurses were negligent in their duty to provide timely
medical care to Regina Capanzana.
Whether the hospital can be held liable for the negligence of its nurses.
Ruling:
The Supreme Court affirmed the decision of the Court of Appeals, holding the
hospital liable for negligence.
Ratio:
The court ruled that the hospital and its nurses were negligent in their duty to
provide timely medical care to Regina. The delay in the administration of oxygen was
the proximate cause of her brain damage. The hospital failed to prove that it
exercised due diligence in the supervision of its nurses, making it directly liable for
their negligence. The court deducted the unpaid hospital bill from the damages
awarded to the spouses Capanzana.
Jarantilla vs. Court of Appeals
After being acquitted in a criminal case, the defendant is still held liable for damages
in a separate civil action filed by the complainant, as the civil liability is based on a
quasi-delict and not on the criminal offense.
Facts:
Private respondent Jose Kuan Sing was sideswiped by a vehicle driven by petitioner
Edgar Jarantilla on July 7, 1971, in Iznart Street, Iloilo City.
Jarantilla was charged with serious physical injuries through reckless imprudence in
Criminal Case No. 47207.
Kuan Sing did not reserve his right to file a separate civil action and participated in
the prosecution of the criminal case.
Jarantilla was acquitted in the criminal case on reasonable doubt.
After the acquittal, Kuan Sing filed a separate civil action against Jarantilla in Civil
Case No. 9976, seeking damages for the same act complained of in the criminal
case.
Jarantilla argued that Kuan Sing's cause of action is barred by the prior judgment in
the criminal case.
The trial court denied Jarantilla's motion to dismiss, suggesting that he bring the
matter to the Supreme Court for review.
Jarantilla filed a petition for certiorari, prohibition, and mandamus in the Supreme
Court, which was dismissed for lack of merit.
Issue:
Can Kuan Sing, who was the complainant in the criminal action and participated in
its prosecution, file a separate civil action for damages after Jarantilla's acquittal?
Ruling:
The court rules in favor of Kuan Sing, affirming his right to file the separate civil
action.
Ratio:
The same act or omission can create two kinds of liability on the part of the
offender: civil liability ex delicto and civil liability ex quasi delicto.
Both types of civil liability may be enforced against the culprit, subject to the caveat
that the offended party cannot recover damages under both types of liability.
In this case, Kuan Sing's separate civil action is based on a quasi-delict, and his
failure to reserve his right to file a separate civil case and his intervention in the
criminal case do not bar him from filing the separate civil action for damages.
The failure of the court to make any pronouncement on the civil liability of the
accused amounts to a reservation of the right to have the civil liability litigated and
determined in a separate action.
The civil liability sought to be recovered through the separate civil action is no longer
based on or arising from the criminal offense but is a quasi-delict.
Therefore, the acquittal of the accused does not extinguish the civil liability based on
a quasi-delict.
Based on these reasons, the court denies Jarantilla's petition and affirms the
decision of the Court of Appeals, ordering him to pay damages to Kuan Sing.
Safeguard Security Agency, Inc. vs. Tangco
A security guard's negligence in shooting a bank customer leads to his conviction for
homicide, and his employer is held solidarily liable for damages due to their failure
to exercise diligence in the selection and supervision of their employee.
Facts:
Safeguard Security Agency, Inc. and Admer Pajarillo are the petitioners.
Lauro Tangco, Val Tangco, Vern Larry Tangco, Van Lauro Tangco, Von Larrie Tangco,
Vien Lari Tangco, and Vivien Lauriz Tangco are the respondents.
On November 3, 1997, Evangeline Tangco went to Ecology Bank, Katipunan Branch,
Quezon City, to renew her time deposit.
Evangeline approached security guard Pajarillo, who was stationed outside the bank,
and pulled out her firearm from her bag to deposit it for safekeeping.
Pajarillo shot Evangeline with his service shotgun, causing her death.
Lauro Tangco, Evangeline's husband, filed a criminal case of Homicide against
Pajarillo, which resulted in his conviction.
The respondents filed a separate civil case for damages against Pajarillo and
Safeguard for negligence.
Issue:
Whether Pajarillo is guilty of negligence in shooting Evangeline.
Whether Safeguard should be held solidarily liable for the damages awarded to the
respondents.
Ruling:
The court found that Pajarillo was guilty of negligence in shooting Evangeline.
The court held that Safeguard is primarily and solidarily liable for the damages
awarded to the respondents.
Ratio:
Pajarillo was negligent in shooting Evangeline as there was no evidence to support
his claim of self-defense.
Pajarillo failed to report any suspicious behavior by Evangeline prior to the shooting.
Safeguard is primarily and solidarily liable for the damages awarded to the
respondents.
As the employer of Pajarillo, Safeguard is presumed to be negligent in the selection
and supervision of its employee.
Safeguard failed to show that it exercised the diligence of a good father of a family in
the supervision of Pajarillo.
Pajarillo was not aware of the company rules and regulations, and there was no
evidence of adequate training and continuous evaluation of his performance.
Therefore, Safeguard's liability is not limited to subsidiary liability, but rather it is
solidarily liable with Pajarillo.
Employers have a duty to exercise diligence in the selection and supervision of their
employees, and failure to do so makes them liable for the acts of their employees.