View full case

PHILIPPINE NATIONAL RAILWAYS v. ETHEL BRUNTY

FACTS:

In this case, Rhonda Brunty, an American citizen, visited the Philippines with her Filipino host Juan Manuel M. Garcia. They were traveling in a Mercedes Benz sedan driven by Rodolfo L. Mercelita when they encountered a collision with a train at a railroad crossing in Barangay Rizal, Moncada, Tarlac. Mercelita died instantly, while Rhonda Brunty and Garcia were injured and hospitalized.

Ethel Brunty, Rhonda Brunty's mother, sent a demand letter to Philippine National Railways (PNR) seeking payment of damages. When PNR did not respond, Ethel Brunty and Garcia filed a complaint for damages against PNR before the RTC of Manila. They alleged negligence on the part of PNR for not providing necessary equipment and failing to properly supervise its employees. They sought various damages, including actual and compensatory damages, moral damages, and attorney's fees.

PNR argued that it exercised due diligence in the selection and supervision of its employees. It claimed the right of way on the railroad crossing and argued that warning signs were in place. PNR also claimed that Mercelita's negligence was the cause of the accident.

During the proceedings, Chemical Industries of the Philippines, Inc. (Chemphil), Garcia's employer, was included as a party plaintiff seeking reimbursement for expenses incurred.

After the trial, the RTC ruled in favor of the plaintiffs, ordering PNR to indemnify the plaintiffs and awarding various damages. PNR appealed to the Court of Appeals, which affirmed the RTC decision with modifications. PNR then filed a petition for review on certiorari before the Supreme Court, challenging the CA decision.

ISSUES:

  1. Whose negligence resulted in the collision?

  2. Is Mercelita guilty of contributory negligence?

  3. Is the doctrine of last clear chance applicable in this case?

  4. Whether or not the petitioner PNR is negligent in failing to provide adequate safety equipment at the railroad crossing.

  5. Whether or not the driver, Mercelita, is guilty of contributory negligence.

  6. Whether or not the doctrine of last clear chance is applicable.

  7. Whether temperate damages can be awarded instead of actual damages.

  8. Whether the relatives of the victim can recover moral damages.

RULING:

  1. The negligence of petitioner, the Philippine National Railways (PNR), resulted in the collision. The court affirmed the findings of the trial court and the Court of Appeals that petitioner failed to provide the necessary safety device to ensure the safety of motorists in crossing the railroad track. As a result, PNR is liable for damages for violating Article 2176 of the New Civil Code.

  2. The issue of whether Mercelita, the driver of the Mercedes Benz, is guilty of contributory negligence was not directly addressed in the ruling. It was mentioned by petitioner in their argument, but the court did not provide a specific ruling on this matter.

  3. The applicability of the doctrine of last clear chance was also not directly addressed in the ruling. Respondents claimed that this issue was being raised for the first time in the petition and argued that there was no basis to apply this doctrine. The court did not explicitly rule on this issue in the ruling.

  4. The Court affirmed the finding of the Court of Appeals (CA) that petitioner PNR is negligent in failing to provide adequate safety equipment at the railroad crossing.

  5. The Court agreed with petitioner PNR that Mercelita is guilty of contributory negligence. However, while Mercelita's acts contributed to the collision, they do not negate petitioner's liability. The only effect of contributory negligence in this case is to mitigate liability, which is not applicable.

  6. The Court ruled that the doctrine of last clear chance is not applicable. The proximate cause of the injury was the negligence of petitioner PNR.

  7. Yes, it is proper to award temperate damages in the amount of P25,000.00 instead of actual damages, in accordance with prevailing jurisprudence.

  8. Yes, the relatives of the victim can recover moral damages in meritorious cases.

PRINCIPLES:

  • Negligence is the omission to do something which a reasonable person would do, or the doing of something which a prudent person would not do.

  • In determining negligence, the standard to be considered is the reasonable care and caution that an ordinarily prudent person would have used in the same situation.

  • Factual findings of the Court of Appeals affirming those of the trial court are conclusive and binding on the Supreme Court.

  • Quasi-delict, governed by Article 2176 of the New Civil Code, requires the concurrence of damage to the plaintiff, negligence on the part of the defendant, and a connection of cause and effect between the negligence and the damage.

  • Railroad companies owe a duty of exercising a reasonable degree of care to avoid injury to persons and property at railroad crossings.

  • Railroad companies are required to provide good, sufficient, and safe crossings at all points where the railway crosses any public road and to erect signs to give notice of the proximity of the railway.

  • Failure to provide safety devices or equipment at a railroad crossing is evidence of negligence and disregard of public safety.

  • Contributory negligence is conduct on the part of the injured party that falls below the standard of care required for their own protection.

  • Negligence is contributory only when it contributes proximately to the injury and not simply a condition for its occurrence.

  • The doctrine of last clear chance applies when both parties are negligent but the negligent act of one is appreciably later than the other or when it is impossible to determine whose fault or negligence caused the loss. The party with the last clear opportunity to avoid the loss but failed to do so is chargeable with the loss.

  • Actual or compensatory damages must be duly proved with a reasonable degree of certainty. Speculation or guesswork is not sufficient.

  • Temperate damages can be awarded instead of actual damages if the latter cannot be proven with certainty, as it would be unfair for the victim's heirs to receive nothing due to the inability to produce receipts.

  • Moral damages are designed to compensate and alleviate the physical suffering, mental anguish, fright, serious anxiety, besmirched reputation, wounded feelings, moral shock, social humiliation, and similar injuries unjustly caused to a person. It is not punitive in nature, but rather proportional to the suffering inflicted.

  • The amount of moral damages awarded should be determined based on the circumstances of the case and recent jurisprudence.