FACTS:

The case involves a collision between a Datsun crewcab driven by Apolonio Deocampo and a Chevy pick-up owned by Michael Raymond Angala and driven by Bernulfo Borres. The crewcab belonged to Lapanday Agricultural and Development Corporation (LADECO) and was assigned to its manager, Manuel Mendez. The accident occurred on Rafael Castillo St., Agdao, Davao City, when the crewcab bumped into the pick-up, causing damage to the left door, front left fender, and part of the front bumper of the pick-up.

Respondent filed a case for Quasi-Delict, Damages, and Attorney's Fees against LADECO, its administrative officer Henry Berenguel, and Deocampo. Respondent claimed that his pick-up was slowing down to make a left turn when it was hit from behind by the crewcab. He alleged that the crewcab was running at a high speed and that he heard a screeching sound before the impact.

Deocampo, on the other hand, claimed that both vehicles were running at about 40 kph and that the pick-up suddenly made a U-turn without giving any signal. He stated that he tried to avoid the pick-up but was unable to do so, and that he only applied the brakes after the collision.

The trial court held LADECO and Deocampo solidarily liable and ordered them to pay damages and attorney's fees. The court found that the crewcab's speed was the proximate cause of the accident and that Deocampo had the last opportunity to avoid the collision.

The Court of Appeals affirmed the trial court's decision, sustaining its findings that Deocampo was negligent and that LADECO and Deocampo were solidarily liable under Article 2180 of the Civil Code.

Petitioners filed a motion for reconsideration, which was denied by the Court of Appeals in its resolution. Hence, the petition was brought before the Supreme Court.

ISSUES:

1. Whether the provisions of Section 45(b) of Republic Act No. 4136 (RA 4136) and Article 2185 of the Civil Code apply to this case.

RULING:

1. The Court ruled that the provisions of Section 45(b) of RA 4136 and Article 2185 of the Civil Code do not apply to this case. These provisions pertain to the determination of liability of the registered owner of a vehicle for damages caused by the negligence of the driver. In the present case, the Court found that LADECO, the registered owner of the vehicle, was not negligent and did not contribute to the cause of the accident. The Court applied the doctrine of last clear chance and found that the negligence of the driver, Deocampo, was the proximate cause of the accident. Therefore, LADECO cannot be held solidarily liable with Deocampo.

PRINCIPLES:

• Section 45(b) of Republic Act No. 4136 (RA 4136) provides that the registered owner of a vehicle is solidarily liable with the driver for damages caused by the latter's negligence.

• Article 2185 of the Civil Code provides that the registered owner of a vehicle is liable for damages caused by the negligence of the driver, unless it is proven that the driver was not negligent.

• The doctrine of last clear chance applies when both parties are negligent, but the negligent act of one party occurs later in time and if the other party had the last clear chance to avoid the accident by the exercise of reasonable care and caution.

• Proximate cause is that cause, which, in natural and continuous sequence, unbroken by any efficient intervening cause, produces the injury and without which the result would not have occurred.