FACTS:
On July 18, 1990, the petitioner entrusted his Nissan pick-up car to the private respondent, a repair shop, for various repair services and the supply of parts. The repair shop guaranteed to return the vehicle fully serviced by July 21, 1990. The petitioner paid the repair bill in full, received a gate pass, and expected to take possession of his car. However, upon trying to retrieve his vehicle on July 21, 1990, the repair shop informed him that the battery still needed replacement. The petitioner purchased a new battery and brought it to the repair shop, but it was not installed. Consequently, the delivery of the vehicle was rescheduled for July 24, 1990.
When the petitioner attempted to claim his car on July 24, 1990, he was informed that it was stolen while being road-tested by an employee of the repair shop. The petitioner filed a lawsuit against the repair shop, alleging negligence, and sought damages. During pre-trial, the parties agreed on certain facts, including the cost and present value of the vehicle. The trial court found the repair shop guilty of delay and held them accountable to the petitioner. However, the Court of Appeals overturned this decision, ruling that the loss of the vehicle was due to a fortuitous event. The petitioner subsequently appealed to the Supreme Court, questioning whether a repair shop can be held liable for the loss of a customer's vehicle while in its custody.
ISSUES:
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Whether the court a quo was limited to resolving the issue of negligence only as agreed during pre-trial.
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Whether the vehicle was lost due to a fortuitous event.
RULING:
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The court a quo was not limited to resolving the issue of negligence only as agreed during pre-trial. The question of delay, though not specifically mentioned as an issue at the pre-trial, may be tackled by the court considering that it is necessarily intertwined and intimately connected with the principal issue agreed upon by the parties. Hence, the court can consider the issue of delay in determining whether there was negligence on the part of the repair shop.
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The repair shop cannot escape liability simply because the loss of the vehicle was due to a fortuitous event. It is not a defense for a repair shop of motor vehicles to avoid liability for the loss of a customer's vehicle while in its custody for repair or other job services.
PRINCIPLES:
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The determination of issues at a pre-trial conference does not limit the court's authority to consider other issues that are necessarily intertwined with the principal issue agreed upon by the parties.
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A repair shop of motor vehicles cannot escape liability for the loss of a customer's vehicle while in its custody for repair or other job services, even if the loss was due to a fortuitous event.