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GUILLANG v. RODOLFO BEDANIA

FACTS:

The case involves a petition for review of the decision of the Court of Appeals in favor of respondents in a complaint for damages based on quasi-delict. The petitioners filed the complaint against the driver and owner of a cargo truck, alleging that the driver was negligent in making a sudden U-turn on the highway without due regard to traffic rules and the safety of other motorists. The collision between the truck and the car resulted in the death of one of the car's passengers.

The trial court found both the driver and the owner of the truck grossly negligent and held them liable for damages. It awarded damages to the petitioners, including repair costs, burial expenses, and medical expenses.

However, the Court of Appeals reversed the trial court's decision, stating that it overlooked substantial facts and circumstances that would justify a different conclusion. The Court of Appeals dismissed the complaint, finding the driver of the car liable for the damages instead. It relied on physical evidence and the testimony of a police traffic investigator to conclude that the negligence of the car driver was the proximate cause of the collision.

The petitioners filed a motion for reconsideration, which was denied by the Court of Appeals. They then filed a petition before the Supreme Court.

ISSUES:

  1. Did the Court of Appeals decide a question of substance in this case in a way probably not in accord with the law or with the applicable decisions of the Supreme Court?

  2. Did the Court of Appeals depart from the accepted and usual course of judicial proceedings by revising and recasting the trial court's findings of fact regarding the credibility of witnesses?

  3. Did the Court of Appeals act with grave abuse of discretion amounting to lack of jurisdiction when it rendered a decision that tampered with the trial court's findings of fact for no justifiable reason?

  4. Is the Court of Appeals' judgment and resolution supported by the evidence and the law and jurisprudence applicable?

  5. Whether the truck encroached upon the car's lane when it made a U-turn

  6. Whether the truck driver's negligence was the proximate cause of the collision

  7. Whether the truck driver's employer is also liable for the damages suffered by the petitioners

  8. Whether the trial court's award of damages is proper

  9. Whether the plaintiff is entitled to moral, temperate, or compensatory damages before the court may consider the award of exemplary damages.

  10. Whether the trial court properly awarded exemplary damages in the amount of P50,000.

  11. Whether the trial court properly awarded attorney's fees in the amount of P100,000.

RULING:

  1. The principle established is that the Supreme Court is not a trier of facts. Therefore, an appeal by certiorari under Rule 45 of the Rules of Court only allows questions of law to be raised. However, there are exceptions to this rule, one of which is when the findings of the appellate court are contrary to the trial court's findings or are not supported by the evidence.

  2. n this case, the Court of Appeals departed from the trial court's findings of fact regarding the negligence and proximate cause of the collision. Notably, the Court of Appeals relied on the testimonial evidence of a witness who gave inconsistent statements and disregarded the police records and report documenting the incident. Thus, the Court of Appeals' judgment and resolution are not supported by the evidence and the law and jurisprudence applicable.

  3. The truck encroached upon the car's lane when it made a U-turn, thereby violating the car's right of way.

  4. The truck driver's negligence was the proximate cause of the collision as his sudden U-turn without signal lights posed a serious risk to oncoming motorists and triggered a series of events that led to the collision.

  5. The truck driver's employer is also liable for the damages suffered by the petitioners as they failed to prove that they exercised all the diligence of a good father of a family in the selection and supervision of their employees.

  6. The trial court's award of damages is proper, including civil indemnity for death, moral damages, funeral and burial expenses, hospitalization expenses, and repair of the car.

  7. Yes, the plaintiff must show that he is entitled to moral, temperate, or compensatory damages before the court may consider the award of exemplary damages.

  8. Yes, the trial court properly awarded exemplary damages in the amount of P50,000 because the defendant's gross negligence in making a sudden U-turn in the highway without signal lights justified the award as an example for the public good.

  9. Yes, the trial court properly awarded attorney's fees in the amount of P100,000 as provided under Article 2208 of the Civil Code because exemplary damages were awarded in the case.

PRINCIPLES:

  • The Supreme Court is not a trier of facts, and only questions of law can be raised in an appeal by certiorari under Rule 45 of the Rules of Court.

  • Findings of fact of the trial court and the Court of Appeals may be set aside if they are contrary to each other or not supported by evidence.

  • Negligence is the failure to observe the degree of care, precaution, and vigilance that the circumstances justly demand, resulting in injury to another person.

  • To sustain a claim based on quasi-delict, the requirements of damage suffered by the plaintiff, fault or negligence of the defendant, and the connection of cause and effect between the defendant's fault or negligence and the plaintiff's damage must be present.

  • Article 2185 of the Civil Code provides that a person driving a vehicle is presumed negligent if, at the time of the mishap, they were violating any traffic regulation.

  • The driver who encroaches upon the lane of another vehicle violates the latter's right of way.

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

  • An employer is also liable for damages caused by the negligence of its employees if it fails to exercise all the diligence of a good father of a family in their selection and supervision.

  • Damages in quasi-delicts may include civil indemnity for death, moral damages, funeral and burial expenses, hospitalization expenses, and repair of property.

  • The plaintiff must demonstrate entitlement to moral, temperate, or compensatory damages before the award of exemplary damages may be considered.

  • Exemplary damages may be awarded to serve as an example for the public good.

  • Attorney's fees may be recovered when exemplary damages are awarded.