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ARNEL GABRIEL v. CA

FACTS:

In the first case, a three-way vehicular collision occurred along Maharlika Highway in San Pablo City, Laguna. Petitioner Arnel Gabriel was found guilty of Reckless Imprudence Resulting to Double Homicide and Damage to Property by the Regional Trial Court (RTC) of San Pablo City. Gabriel appealed to the Court of Appeals, which modified the RTC's decision by finding Gabriel liable for Reckless Imprudence Resulting to Multiple Homicide. The collision involved a jeepney, a Volkswagen Beetle car, and a six-wheeler Isuzu delivery truck. Three people died in the accident, including Dr. Philip Plantilla, the director of Nagcarlan District Hospital. Gabriel admitted driving the jeepney and claimed that the collision was caused by the Beetle bumping into his jeepney. The prosecution alleged that the jeepney was traveling at high speed on the wrong lane, causing the collision.

In the second case, a collision occurred between a truck owned by petitioner Pablito Gabriel and a motorcycle driven by respondent Edwin Toribio along Maharlika Highway in Tayug, Pangasinan. The truck driver testified that the motorcycle suddenly swerved into the truck's lane, causing the collision. On the other hand, Toribio's widow argued that the truck encroached on the motorcycle's lane and that her husband could not have seen it approaching due to dim headlights. The Regional Trial Court (RTC) ruled in favor of Gabriel, finding Toribio solely responsible for the collision due to reckless driving. The Court of Appeals (CA) affirmed the RTC's decision, considering the truck driver's testimony as credible and finding no sufficient evidence to support the widow's claim.

In both cases, the RTC's decision was affirmed by the Court of Appeals and the Supreme Court dismissed the petitions seeking to overturn the lower courts' decisions. The Supreme Court noted that the factual findings of the lower courts were consistent and that there was sufficient evidence to establish the accused's guilt in the first case and the motorcycle driver's negligence in the second case.

ISSUES:

  1. Whether the first collision between the Beetle and the jeepney occurred on the San Pablo-bound lane.

  2. Whether the testimony of Macabuhay, a witness to the first collision, is credible.

  3. Whether the testimonies of Marquez and Gonzales, the defense witnesses, are credible.

  4. Whether the testimony of Gonzales, a witness presented by the defense, is credible.

  5. Whether the police sketch of the accident scene, prepared by Patrolman Laguras, accurately depicts the location of the debris field.

  6. Whether Gabriel's conduct of veering into the wrong lane and speeding constitutes reckless imprudence resulting in homicide.

  7. Whether Gabriel should be held liable for double homicide or reckless imprudence resulting in multiple homicide.

  8. Whether the awards for damages are proper.

  9. Whether temperate damages may be awarded for the damage to the Volkswagen car.

  10. Whether the award of actual damages for hospitalization expenses is justified.

  11. Whether the formula for computing loss of earning capacity is correctly applied.

  12. Whether there is sufficient proof of Asistido's monthly income for the purpose of computing loss of earning capacity.

RULING:

  1. The first collision between the Beetle and the jeepney occurred on the San Pablo-bound lane. The RTC and the Court of Appeals found clear and convincing evidence supporting this conclusion.

  2. The testimony of Macabuhay, the witness to the first collision, is credible. There is no evidence to dispute his credibility or impartiality.

  3. The testimonies of Marquez and Gonzales, the defense witnesses, are not credible. Marquez is biased as he is a friend of Gabriel's. Gonzales's testimony is incredulous and inconsistent with the laws of nature.

  4. The testimony of Gonzales, a witness presented by the defense, is not credible. His recitals regarding the accident were biased and inconsistent with the prosecution's version. His testimony was tailored to contradict the prosecution's account rather than to manifest what actually happened.

  5. The police sketch, disputed only through the testimony of Gonzales, is considered accurate and reliable. The location of the debris field shown in the sketch supports the prosecution's claim that the first collision occurred on the San Pablo-bound lane.

  6. Gabriel's conduct of veering into the wrong lane and speeding constitutes reckless imprudence. His actions were the proximate cause of the fatal accident.

  7. Gabriel should be held liable for double homicide, not reckless imprudence resulting in multiple homicide. The charges in the information only seek to hold him liable for the deaths of Pitargue and Asistido. The Court of Appeals' ruling that Gabriel is guilty of reckless imprudence resulting in multiple homicide is erroneous.

  8. The award of Ten Thousand Pesos (P10,000.00) to Dr. Plantilla for damages is deleted as it is not supported by reliable evidence. The award of Fifty Thousand Pesos (P50,000.00) to Dr. Plantilla for actual damages to his Beetle is warranted, although it should be based on competent proof or the best evidence obtainable.

  9. Temperate damages in the amount of Forty Thousand Pesos (P40,000.00) are awarded for the damage to the Volkswagen car.

  10. The award of actual damages for hospitalization expenses is justified.

  11. The formula for computing loss of earning capacity is not correctly applied. The correct award for the loss of earning capacity to the heirs of Pitargue is Eighty-Six Thousand Two Hundred Six Pesos (P86,206.00), while that owing to the heirs of Asistido is Sixty-Two Thousand Three Hundred Eighty-Eight Pesos (P62,388.00).

  12. There is sufficient proof of Asistido's monthly income for the purpose of computing loss of earning capacity.

PRINCIPLES:

  • Clear and convincing evidence is necessary to support a conclusion in a case.

  • Witnesses who have a bias or interest in the outcome of the case may have their testimonies questioned for credibility.

  • The laws of nature and common sense should be considered when evaluating witness testimonies.

  • The credibility of a witness is crucial in criminal cases, especially when a defendant's liberty is at stake. Biased witnesses posing as neutral observers undermine the integrity of the justice system.

  • Evidence showing the position of vehicles immediately after an accident can throw light on the speed and direction of their movements prior to and at the time of the accident.

  • Excessive speed combined with other circumstances, such as the occurrence of an accident on or near a curve, may constitute negligence.

  • The real nature of a criminal charge is determined by the actual recital of facts in the complaint or information, not by its caption or preamble or the specification of the law alleged to have been violated.

  • To recover actual damages, the amount of loss must be proven with competent proof or the best evidence obtainable. An indefinite cost estimate cannot suffice.

  • Temperate damages may be awarded when the amount of actual damages cannot be established with certainty.

  • Actual damages may be awarded based on the evidence presented, such as hospital bills and receipts.

  • The formula adopted in Villa Rey Transit v. Court of Appeals applies to cases of wrongful death in order to determine the appropriate amount of actual damages due to the heirs, based on life expectancy and the rate at which losses sustained should be fixed.

  • The absence of documentary evidence does not preclude recovery of damages for loss of earning capacity. Testimonial evidence may be sufficient basis for determining compensatory damages.