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ARMANDO JOSE T PAZ v. CA

FACTS:

The case involves a vehicular accident between Bus 203, owned by Manila Central Bus Lines Corporation (MCL), and a red Ford Escort driven by John Macarubo. The accident occurred on February 22, 1985, in Valenzuela, Metro Manila. The Ford Escort sustained severe damage to its left side, and both John Macarubo and his passenger, Rommel Abraham, were seriously injured. John Macarubo eventually died from his injuries, while Rommel Abraham lost vision in his left eye and suffered other injuries.

Rommel Abraham filed a civil case for damages against MCL and Armando Jose, the driver of Bus 203. Additionally, the parents of John Macarubo filed their own suit for damages against MCL. The trial court dismissed the cases against MCL and ruled in its favor on its third-party complaint against Juanita Macarubo, the registered owner of the Ford Escort.

However, the Court of Appeals overturned the trial court's decision and ordered MCL and Armando Jose to pay damages to Rommel Abraham and the Macarubo family. MCL and Armando Jose then filed a petition for review on certiorari, questioning the finding of fault for the collision.

ISSUES:

  1. Whether the physical evidence should prevail over the testimonial evidence of the prosecution witnesses in determining the truth of the collision between Bus 203 and the Ford Escort.

  2. Whether the photographs taken after the collision accurately depict the positions of the vehicles at the time of the collision.

  3. Whether the Ford Escort encroached on the opposite lane occupied by Bus 203.

  4. Whether the mechanical defect in the Ford Escort's rear cross-joint caused the driver to lose control of the vehicle.

  5. Whether the bus company and its driver can be held liable for damages caused by the bus's collision with a car.

  6. Whether the registered owner of the car can be held vicariously liable for the negligence of the car's driver.

RULING:

  1. Yes. In People v. Vasquez, it was ruled that physical evidence should prevail over testimonial evidence when they are in conflict.

  2. Yes. The positions of the vehicles shown in the photographs taken after the collision dispute the testimony of the defendant and show that the Ford Escort encroached on the opposite lane occupied by Bus 203.

  3. Yes. The photographs clearly show that the Ford Escort was positioned diagonally on the highway with its two front wheels occupying Bus 203's lane, contradicting the defendant's testimony.

  4. It is highly likely. The defendant himself testified that the Ford Escort's rear cross-joint was cut/detached and was hastily repaired by welding. This suggests a serious mechanical problem that could have caused the driver to lose control of the vehicle.

  5. The bus company and its driver cannot be held liable for damages caused by the collision. The court found that there was no concrete evidence to prove the negligence of the bus driver, as well as the failure of the bus company to exercise due diligence in the selection and supervision of its employees. The presumption of negligence of the employer cannot arise without first proving the negligence of the employee. Therefore, the complaint against the bus company and its driver was dismissed.

  6. The registered owner of the car cannot be held vicariously liable for the negligence of the car's driver. The court ruled that there was no allegation or evidence presented to establish an employer-employee relationship between the registered owner and the driver. Merely authorizing someone to use a vehicle does not make the authorized person an employee. Therefore, the third-party complaint against the registered owner of the car was also dismissed.

PRINCIPLES:

  • The physical evidence should prevail over testimonial evidence when they are in conflict.

  • Photographs taken after an accident can be used as evidence to accurately depict the positions of the vehicles at the time of the accident. However, the time gap between the accident and the taking of the photographs should be taken into consideration.

  • In determining liability in a collision case, it is important to consider the positioning of the vehicles at the time of the collision.

  • Mechanical defects in a vehicle can cause the driver to lose control and affect the maneuverability of the vehicle. Such defects should be treated seriously and repaired properly to ensure the safety of the driver and others on the road.

  • The diligence of a good father of a family is required of employers to prevent damage caused by their employees. Presumed negligence of the employer in the selection and supervision of employees arises unless the employer proves otherwise.

  • Vicarious liability of the registered owner of a car for the negligence of the driver is based on an employer-employee relationship. Mere authorization to use the vehicle does not make the authorized person an employee.