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DRA. LEILA A. DELA LLANA v. REBECCA BIONG

FACTS:

On March 30, 2000, Juan dela Llana, along with his sister and a passenger, was driving their car when it was rammed by a dump truck driven by Joel Primero. The traffic investigation found Joel to be recklessly imprudent. It was later revealed that Joel's employer was Rebecca Biong, doing business as "Pongkay Trading."

Dra. dela Llana, who was injured in the accident, experienced pain in her neck and shoulder. Despite seeking medical consultations and undergoing therapy, her condition did not improve. She eventually underwent surgery, which resolved the nerve impingement but left her unable to practice her profession.

Dra. dela Llana demanded compensation from Rebecca, but the latter refused to pay. As a result, Dra. dela Llana filed a lawsuit seeking damages for her injuries.

During the trial, Dra. dela Llana presented medical evidence and testimony supporting her claim that her injury was a direct result of the accident caused by Joel's recklessness. On the other hand, Rebecca argued that there was no reasonable relation between the accident and Dra. dela Llana's injury.

The regional trial court ruled in favor of Dra. dela Llana, finding Joel's reckless driving to be the proximate cause of her injury. The court also considered the significant damage to the car as evidence of overspeeding by the truck. However, the Court of Appeals (CA) reversed the trial court's decision, stating that there was no reasonable connection between the accident and Dra. dela Llana's whiplash injury. The CA noted the lengthy interval between the accident and when Dra. dela Llana started experiencing symptoms.

Dra. dela Llana appealed the CA's decision, arguing that the ruling in Nutrimix Feeds Corp. v. Court of Appeals does not apply to her case. She claimed to have presented sufficient evidence, including pictures of her damaged car, a medical certificate, and her own testimony, to establish causation. Rebecca countered that the CA's findings are final and that Dra. dela Llana's arguments are not substantial.

ISSUES:

  1. Whether Joel's reckless driving is the proximate cause of Dra. dela Llana's whiplash injury.

RULING:

  1. The Supreme Court ruled that Dra. dela Llana failed to establish her case by preponderance of evidence. The petitioner did not sufficiently show the causal relationship between Joel's reckless driving and her whiplash injury. The evidence presented, including pictures of her damaged car and a medical certificate, was either inadmissible or lacked probative value to prove the causal connection between the vehicular accident and her injury. Consequently, the claim was unsupported by sufficient evidence.

PRINCIPLES:

  • The Rule 45, Rules of Court: The Supreme Court generally does not review factual findings unless there is a conflict between findings of the RTC and the CA.

  • Article 2176, Civil Code: Elements necessary to establish a quasi-delict case include (1) damages to the plaintiff, (2) negligence (by act or omission) of the defendant, and (3) the causal connection between such negligence and the damages.

  • Burden of Proof in Civil Cases: The party alleging a fact has the burden of proving it by preponderance of evidence.

  • Evidence Admissibility: Evidence not admitted during trial cannot be considered by the courts in their judgments.

  • Hearsay Rule: Evidence whose probative value is not based on the personal knowledge of the witness but on the knowledge of another person not on the witness stand is considered hearsay and generally inadmissible.

  • Difference Between Ordinary and Expert Witness: The opinion of an ordinary witness through observed facts vs. the opinion of an expert witness on matters requiring special knowledge, skill, experience, or training.

  • Judicial Notice: Courts do not take judicial notice that vehicular accidents cause whiplash injuries as this is not public knowledge or capable of unquestionable demonstration.