**Facts:**
The accident occurred on March 30, 2000, when Juan dela Llana, with his sister Dra. Leila A. dela Llana and another passenger, Calimlim, was rear-ended by a dump truck driven by Joel Primero and owned by respondent Rebecca Biong, who operates Pongkay Trading. Originally, Dra. dela Llana only sustained minor injuries. However, she later developed severe pain leading to a diagnosis of a whiplash injury caused by the accident, eventually requiring cervical spine surgery, and causing a loss in her professional capacity.
Dra. dela Llana demanded compensation from Biong, which was refused, leading to the filing of a damages case with the Regional Trial Court of Quezon City (RTC) on May 8, 2001. Biong contended that there was no reasonable connection between the accident and Dra. dela Llana’s injuries. The RTC eventually ruled in favor of Dra. dela Llana, identifying Primero’s reckless driving as the proximate cause of the injury and holding Biong vicariously liable based on employer-employee relationship principles.
However, the Court of Appeals (CA) reversed this decision, concluding that Dra. dela Llana failed to establish a reasonable connection between the vehicular accident and her injury. Dra. dela Llana then filed a petition for review on certiorari with the Supreme Court.
**Issues:**
1. Whether the CA erred in reversing the RTC’s decision due to a supposed failure of establishing a connection between the accident and Dra. dela Llana’s injuries.
2. Whether Joel Primero’s reckless driving was the proximate cause of Dra. dela Llana’s whiplash injury.
**Court’s Decision:**
The Supreme Court denied the petition, affirming the CA’s decision. The Court held that questions of fact are not usually reviewed in petitions for review on certiorari unless there are conflicting findings between the lower courts, which was applicable in this case. However, upon review, the Supreme Court found that Dra. dela Llana failed to establish the proximate cause of her injuries through preponderance of evidence, a crucial element in a quasi-delict case. Evidence such as pictures of the damaged car, the medical certificate, and Dra. dela Llana’s testimony did not conclusively prove the causal link between the accident and the injury.
**Doctrine:**
– In civil cases, particularly in quasi-delict claims, the plaintiff must establish by preponderance of evidence the elements of damages, negligence, and the causal connection between the two.
– Findings of fact of the Court of Appeals are final and conclusive and are not reviewed on appeal to the Supreme Court, except in cases where the findings of the trial court and the appellate court conflict.
– Evidence not admitted by the trial court cannot be considered in resolving the case.
**Class Notes:**
– Quasi-Delict Requirements: (1) damages suffered by the plaintiff; (2) fault or negligence of the defendant, or of someone for whom the defendant is responsible; (3) causal connection between the fault or negligence and the damages incurred.
– Preponderance of Evidence: The party who alleges a fact must prove it by preponderance of evidence, meaning the evidence must be more convincing than the evidence offered in opposition.
– Employer Liability in Quasi-Delicts: Employers can be held vicariously liable for the negligent acts of their employees if the negligent act occurs within the scope of the employee’s duties.
**Historical Background:**
This case reflects the principles of vicarious liability and negligence under the Philippine Civil Code, where establishing a clear causal link between the act of negligence and the resulting damages is pivotal for a successful claim. It underscores the judiciary’s careful balancing act in attributing liability, particularly in complex cases involving delayed onset injuries where the connection between cause and effect is not immediately apparent.
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