FACTS:

The case involves a collision between a bicycle and a car. The cyclist, Añonuevo, was struck by the vehicle driven by Villagracia while the cyclist was riding his bicycle. Añonuevo filed a lawsuit against Villagracia seeking damages for the injuries he sustained. Añonuevo relied on Article 2185 of the Civil Code which holds motor vehicle owners and operators liable for damages caused by their vehicles. Villagracia, however, argued that Article 2185 should not apply to non-motorized vehicles like bicycles. He claimed that the provision was specifically designed for motor vehicles and the higher standard of care applicable to them. Villagracia further argued that even if Article 2185 does not apply, he may still be found negligent for failing to comply with traffic regulations.

ISSUES:

1. Whether or not Art. 2185 of the Civil Code applies to non-motorized vehicles.

2. Whether or not Villagracia was negligent for failing to comply with traffic regulations.

3. Should the doctrine of negligence per se apply to Villagracia, resulting from his violation of an ordinance?

4. Is Villagracia's violation of the ordinance a contributing cause of the accident?

5. Whether the failure of the bicycle owner to comply with accepted safety practices is sufficient to negate or mitigate recovery.

6. Whether the absence of lights on a bicycle and the absence of effective brakes constitute negligence barring or diminishing recovery.

7. Whether the alleged negligence of the bicycle owner was the proximate or contributory cause of the accident.

8. What is the issue raised by the petitioner in this case?

9. What is the issue raised by the respondent in this case?

RULING:

1. Art. 2185 of the Civil Code does not apply to non-motorized vehicles. The provision was formulated to impose a higher degree of diligence and care on motorized vehicles due to their special nature. The distinction between motorized and non-motorized vehicles is necessary to recognize this higher standard of care. Therefore, the contention that Art. 2185 should apply to non-motorized vehicles is unsupported.

2. Even though the legal presumption under Art. 2185 does not apply to Villagracia, his possible negligence should still be considered. The existence of negligence is determined by the law and not personal judgment. Villagracia's admission of the imputed negligent acts warrants serious consideration. The violation of traffic regulations could be a basis for finding negligence under the principle of negligence per se.

3. The doctrine of negligence per se should not apply to Villagracia, resulting from his violation of an ordinance. While the violation of the ordinance may establish some degree of negligence on his part, such negligence is without legal consequence unless it is shown to be a contributing cause of the accident.

4. Villagracia's violation of the ordinance is not a contributing cause of the accident. The negligence of Añonuevo, who was speeding and made a reckless left turn, was the proximate cause of the accident. Even if Villagracia's bicycle was equipped with headlights or horns, it is unlikely that he would have avoided injury given Añonuevo's reckless behavior.

5. The failure of the bicycle owner to comply with accepted safety practices, whether or not imposed by ordinance or statute, is not sufficient to negate or mitigate recovery unless a causal connection is established between such failure and the injury sustained.

6. The absence of proper lights on a bicycle at night, as required by statute or ordinance, may constitute negligence barring or diminishing recovery if the absence of such lights was a proximate cause of the collision. A bicycle equipped with defective or ineffective brakes may support a finding of negligence barring or diminishing recovery by an injured bicyclist where such condition was a contributing cause of the accident.

7. The party claiming negligence must establish a causal link, although not proximate, between the negligence of the other party and the injury. The violation of a traffic statute must be shown as the proximate cause of the injury or that it substantially contributed thereto. The burden of proof lies on the party alleging negligence.

8. The issue raised by the petitioner in this case is denied.

9. The issue raised by the respondent in this case is affirmed.

PRINCIPLES:

• Art. 2185 of the Civil Code applies to motorized vehicles and imposes a higher standard of care on them due to their special nature.

• Negligence is determined by the law and not personal judgment.

• Violation of traffic regulations can be considered negligence per se, as it constitutes a breach of duty prescribed by law.

• Negligence per se arises from the violation of a statute or ordinance and does not establish liability for damages unless it is a contributing cause of the injury.

• Negligence is relative and must be determined based on the behavior of the parties in relation to the contemporaneous circumstances of the accident.

• Presumptions in law, such as negligence per se, can be rebutted by factual evidence.

• Tort law aims to provide compensation for the harm suffered by those whose interests have been invaded by the conduct of others.

• The failure of a bicycle owner to comply with accepted safety practices does not negate or mitigate recovery unless a causal connection is established.

• The absence of proper lights on a bicycle and defective brakes may constitute negligence barring or diminishing recovery.

• The violation of a traffic statute must be the proximate cause or substantially contribute to the injury to establish negligence.

• Negligence is contributory only when it contributes proximately to the injury.

• The court affirmed the decision of the Court of Appeals.

• Costs are to be shouldered by the petitioner.