## FACTS:

In the first case, Lourdes Valenzuela filed a complaint to recover damages for the physical injuries she sustained in a vehicular accident. Valenzuela's car was parked along the sidewalk when it was hit by a car driven by Richard Li, causing her severe injuries. The trial court found Li guilty of gross negligence and held him and his employer, Alexander Commercial, Inc., jointly and severally liable for damages. The court ordered them to pay Valenzuela various amounts, including actual damages and monthly support. Li and Alexander Commercial, Inc. appealed, but the Court of Appeals absolved the latter from liability, although it increased the amount of moral damages. Both parties appealed the decision, and the Supreme Court found Li grossly negligent. The court upheld the Court of Appeals' ruling on Alexander Commercial, Inc.'s liability but increased the moral damages awarded to Valenzuela.

In the second case, Valenzuela filed a complaint for damages against Li, alleging that the accident was caused by his negligent and reckless driving. An eyewitness testified that Li was driving at a fast speed, contradicting Li's claim. The trial court relied on the witness's testimony and rejected Li's self-serving version of events. The court concluded that Li's alleged speed and possible influence of alcohol caused the accident.

In the third case, a collision occurred between a bus owned by Happy Bus Company and a taxi cab owned by Bumping Taxi Services. Respondent filed a complaint for damages against petitioner, alleging that the bus driver was negligent. The bus driver testified that the taxi cab suddenly swerved in front of the bus, while the taxi cab driver testified that the bus driver failed to yield the right of way. After conflicting testimonies and opinions from expert witnesses, the trial court ruled in favor of respondent, holding that the bus driver was negligent in not exercising proper caution to avoid the collision. Petitioner appealed to the Court of Appeals, which affirmed the trial court's decision. Petitioner then filed a petition for review with the Supreme Court to reverse the Court of Appeals' decision.

## ISSUES:

1. Whether Richard Li should be held liable for damages for the injuries sustained by Ma. Lourdes Valenzuela due to the vehicular accident.

2. Whether Alexander Commercial, Inc., the employer of Richard Li, should be jointly and severally liable for the damages caused by Li.

## RULING:

1. Richard Li was held liable for the injuries sustained by Ma. Lourdes Valenzuela. The Supreme Court concurred with the findings of the Court of Appeals and the trial court, identifying Li's gross negligence in driving the Mitsubishi Lancer. Despite his contentions, the Court noted that the factual findings of negligence were sustained by ample evidence, including witness testimonies that noted his fast driving and possible influence of liquor.

2. Alexander Commercial, Inc. was held jointly and severally liable with Li for the damages caused due to the accident. The Supreme Court applied the principle of "bonus pater familias" and concluded that Alexander Commercial, Inc. did not demonstrate that it exercised the diligence of a good father in entrusting the company car to Li. It was proven that Li was using the car at the time of the accident, which although for personal use, could not be fully detached from his employment purposes that generally involved representation of the company, hence making the company liable.

## PRINCIPLES:

1. Gross Negligence: The Court found Richard Li to be grossly negligent, which directly caused the injuries sustained by Valenzuela.

2. Vicarious Liability: Under the doctrine of "respondeat superior" and "bonus pater familias," an employer can be held liable for the acts of its employees if the act is done within the scope of employment or even during activities that could benefit the employer.

3. Duty of Care: The necessity of maintaining a standard of care while driving, which is expected to be adhered to by every driver regardless of the conditions.

4. Contributory Negligence: Addressing whether the injured party contributed to their own injuries, but in this case, Valenzuela was found not guilty of contributory negligence as her stop due to a flat tire was regarded as a necessary act under the circumstances.

5. Emergency Rule: Under certain emergency situations, an individual is not held to the same standard of care that is typically expected under normal circumstances, allowing for reasonable actions that may not necessarily align perfectly with legal expectations.

6. Moral Damages: The court adjusted the moral damages awarded considering the severity and the lifetime impact of the injuries sustained, emphasizing that moral damages should properly reflect the extent of pain and suffering incurred.