View full case

EDNA A. RAYNERA v. FREDDIE HICETA

FACTS:

Edna Raynera, the petitioner, was the widow of Reynaldo Raynera and the mother and legal guardian of the minors Rianna and Reianne Raynera. Freddie Hiceta and Jimmy Orpilla, the respondents, were the owner and driver, respectively, of an Isuzu truck-trailer with plate No. NXC 848. The accident occurred on March 23, 1989, at around 2:00 in the morning, when Reynaldo Raynera, who was riding a motorcycle, collided with the left rear portion of the truck trailer. Reynaldo sustained head injuries and was rushed to the hospital where he was pronounced dead on arrival. At the time of his death, Reynaldo was the manager of the Engineering Department of Kawasaki Motors (Phils.) Corporation. The heirs of Reynaldo demanded payment of damages from the respondents, but the respondents refused to pay. As a result, the petitioners filed a complaint for damages against the respondents, alleging that the death of Reynaldo was caused by the negligent operation of the truck-trailer at night without tail lights. The trial court rendered a decision in favor of the petitioners, finding the respondents negligent, and held them jointly and severally liable to pay damages. The trial court also considered the victim's contributory negligence, reducing the responsibility of the respondents by 20%.

ISSUES:

  1. Whether the findings of the Court of Appeals are contrary to those of the trial court.

  2. Whether the respondents are negligent in the operation of the truck-trailer.

  3. Whether the petitioners are entitled to damages.

RULING:

  1. Yes. The principle that factual findings of the Court of Appeals are generally considered final and may not be reviewed on appeal is subject to certain exceptions, including when the findings of the appellate court are contrary to those of the trial court. In this case, the trial court found the respondents negligent while the Court of Appeals reversed this decision. Thus, a re-examination of the facts and evidence is necessary.

  2. Yes. The trial court correctly found the respondents negligent. The truck-trailer was without tail lights and improperly parked in a dark area, posing a danger to other motorists. The installation of only two pairs of red lights, 50 watts each, on both sides of the steel plates was not sufficient. The negligence of the respondents was the immediate and proximate cause of the death of Reynaldo Raynera.

  3. Yes. The petitioners are entitled to damages. The respondents are jointly and severally liable to pay damages to the petitioners for the death of Reynaldo Raynera caused by their negligence.

PRINCIPLES:

  • Factual findings of the Court of Appeals are generally considered final and may not be reviewed on appeal, but there are exceptions when the findings are contrary to those of the trial court.

  • Negligence of the respondent in the operation of a vehicle can make them liable for damages caused by such negligence.

  • The immediate and proximate cause of an injury or death may be attributed to the negligence of one or more parties.

  • Joint and several liability may be imposed on parties who are found to be negligent and liable for damages.