FACTS:

The case involves a vehicular accident that occurred on March 20, 2004, involving two vehicles driven by Jefferson Cham and owned by Arnold Cuaresma and driven by Jerry B. Cuaresma. The vehicle driven by Cham was insured with petitioner Standard Insurance Co., Inc. The accident resulted in damage to Cham's vehicle, which was repaired at the cost of the insurer. Cham executed a Release of Claim in favor of petitioner, subrogating the latter to all his rights to recover on all claims and demands arising from the accident. Petitioner demanded payment from respondents for the cost of repairs. Meanwhile, a criminal case for Reckless Imprudence Resulting in Damage to Property was filed against Cham. Subsequently, petitioner filed a Civil Case for Sum of Money against respondents, claiming payment for the cost of repairs. Respondents were declared in default, and petitioner was allowed to present evidence exparte. The Metropolitan Trial Court ruled in favor of petitioner, but the Regional Trial Court reversed the decision. The Court of Appeals affirmed the RTC's decision. Petitioner now seeks a reversal of the CA's decision, contending that its evidence is sufficient to prove its claims. Respondents argue that petitioner failed to prove negligence and committed forum shopping.

ISSUES:

1. Whether the Court of Appeals erred in affirming the conclusions of the Regional Trial Court that petitioner's evidence is insufficient to prove its claims by the required quantum of evidence.

RULING:

1. The Supreme Court ruled that the petitioner's evidence, including the testimony of its assured and the Assistant Vice-President for Claims, as well as the Traffic Accident Report, were insufficient to prove its claims by the required quantum of evidence. The testimonies and documents presented did not adequately establish negligence on the part of the respondents.

PRINCIPLES:

• Forum Shopping The accused in a criminal action can file a separate civil action independently of the criminal case without being guilty of forum shopping, as per the ruling in Casupanan v. Laroya.

• Preponderance of Evidence In civil cases, the burden of proof lies on the party making the allegations, who must rely on the strength of their own evidence rather than the weakness of the opponent's defense. Preponderance of evidence must convince the court as more credible than that which is offered in opposition.

• Subrogation A subrogee acquires no greater rights than the subrogor and can only recover if the subrogor could have recovered. The substitution gives the subrogee the same rights related to a debt or claim, including remedies or securities, that the subrogor had.

• Traffic Accident Investigation Report For such reports to be admissible as prima facie evidence, the public officer who prepared it must have personal knowledge of the facts stated, acquired either personally or through official information. The absence of the officer's testimony or an explanation for the absence weakens the probative value of the report.