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MARIKINA AUTO LINE TRANSPORT CORPORATION v. PEOPLE

FACTS:

Erlinda Valdellon's commercial apartment was struck by a passenger bus owned and operated by Marikina Auto Line Transport Corporation (MALTC), with Freddie Suelto as its driver. The terrace of Valdellon's apartment suffered extensive damage, which was inspected and reported by Sergio Pontiveros, the Senior Building Inspection Officer. Engr. Jesus Regal, Jr. estimated the cost of repairs to be P171,088.46. Valdellon demanded payment from the bus company and Suelto, but they only offered a P30,000.00 settlement, which she refused. Valdellon filed a criminal complaint against Suelto for reckless imprudence resulting in damage to property, as well as a separate civil complaint for damages against Suelto and the bus company. During the trial, Valdellon presented evidence on the damage caused to the terrace, Pontiveros testified on the need to demolish the building, and Regal estimated the repair costs. Suelto testified that the accident occurred on October 3, 1992.

The trial court found Suelto guilty beyond reasonable doubt and ordered MALTC and Suelto to pay P150,000 to Valdellon as actual damages, and sentenced Suelto to one year imprisonment. MALTC and Suelto appealed the decision to the Court of Appeals (CA), which affirmed the trial court's decision but reduced the award for actual damages to P100,000. The CA's decision was partially granted by the Supreme Court, affirming Suelto's guilt but reducing the award for actual damages to the amount proved by Valdellon, which was P35,000.

The case involved Suelto and MALTC, who were charged with reckless imprudence resulting in damage to property. Suelto testified that he swerved the bus to avoid a passenger jeepney that crossed into his lane, causing a collision with Valdellon's terrace. Architect Arnulfo Galapate estimated the cost of repair to be P55,000.

According to the trial and appellate courts, the petitioners failed to prove that Suelto acted in response to an emergency situation caused by the sudden intrusion of a passenger jeepney. Thus, the burden was not met to show that the damage to the terrace was not Suelto's fault.

ISSUES:

  1. Whether the petitioner is liable for damages caused to the private respondent's property.

  2. Whether the accused is liable for damages due to negligence

  3. Whether the amount of actual damages awarded is reasonable

  4. Whether the claim of private respondent regarding the amount of losses incurred should be accepted as truth.

  5. Whether private respondent presented adequate and competent proof of the pecuniary loss.

  6. Whether the trial court erred in sentencing petitioner Suelto to suffer a straight penalty of one year.

RULING:

  1. The court finds that the petitioner is liable for damages caused to the private respondent's property. The evidence presented showed that the petitioner admitted to swerving the bus to the right, causing it to hit the column of the terrace. The burden of proof was on the petitioner to show that the damage was not his fault, which he failed to do. The court also noted that the petitioner's defense of acting on an emergency was not proven and that he violated traffic regulations by swerving to the right. The trial court correctly rejected the petitioner's defense.

  2. The accused is liable for damages due to negligence. The court found that the accused's swerving and failure to make a full stop indicates a lack of prudence and diligence. The claim of sudden emergency was deemed futile.

  3. The amount of actual damages awarded is not reasonable. The trial court and the appellate court failed to provide a factual basis for the amount awarded. The lack of evidence and explanation led the court to decrease the award to a reasonable amount.

  4. The court admitted the claim of private respondent regarding the losses incurred with caution, as it should be supported by independent evidence. The valuation of the equipment, cargo, and vessel should not be accepted as gospel truth.

  5. Private respondent failed to present adequate and competent proof of the pecuniary loss. The estimated amount needed for repair of the roof of their building was not sufficient, and it was undeterminable whether the damages were solely caused by petitioner's negligence.

  6. The trial court erred in sentencing petitioner Suelto to a straight penalty of one year. Under Article 365 of the Revised Penal Code, the offender should be sentenced to pay a fine when the act resulted in damage to property.

PRINCIPLES:

  • The burden of proof is on the party asserting a claim or defense.

  • Violation of traffic regulations may give rise to the presumption of negligence.

  • Inconsistencies in testimony and prior statements may affect the credibility and reliability of a witness.

  • Inconsistency in a witness's testimony and prior statements affects his credibility.

  • Actual damages must be proven with a reasonable degree of certainty and based on competent and best available evidence.

  • Damages cannot be presumed, and specific facts must be presented as a basis for measuring compensatory damages.

  • Testimonials in support of claims for damages should be viewed with caution and should be supported by independent evidence.

  • Claims should be supported by independent evidence.

  • Losses must be actually proved with a reasonable degree of certainty.

  • The offender should be sentenced to pay a fine when the act resulted in damage to property.