Facts: On January 13, 1991, Ray Castillon borrowed his brother Joel’s motorcycle and, with Sergio Labang as a back rider, went for a ride in Iligan City. After dining and drinking beer, they sped along the highway. Their motorcycle collided with a Tamaraw jeepney owned by Nelen Lambert and driven by Reynaldo Gamot when it abruptly turned left without signaling. Ray Castillon died instantly, while Sergio Labang sustained injuries. The heirs of Ray initiated a damages action against Lambert, leading to a trial that culminated in the RTC’s decision on June 29, 1993, favoring the plaintiffs but acknowledging Castillon’s contributory negligence, thus reducing Lambert’s liability by 20%. Dissatisfied, Lambert appealed to the Court of Appeals, which upheld the RTC’s decision, prompting her to escalate the matter to the Supreme Court through a petition for review.
Issues:
1. Whether Lambert’s driver, Reynaldo Gamot’s sudden left turn without properly signaling was negligently executed, thereby constituting the proximate cause of the accident.
2. Whether the presumption that drivers who bump the rear of another vehicle are the cause of the accident is applicable in this case.
3. The correct computation for the loss of earning capacity of Ray Castillon.
4. The legality of the trial court’s award of moral damages and attorney’s fees.
Court’s Decision:
1. The Supreme Court held that Reynaldo Gamot’s unexpected left turn without first ensuring his right of way was the proximate cause of the accident. It distinguished the case from Raynera v. Hiceta, clarifying that the presumption of the rear vehicle’s driver’s fault does not apply if contradicted by evidence of another’s negligence, such as Gamot’s in this case.
2. The Court affirmed that Ray Castillon was also contributory negligent due to speeding and tailgating, which contributed to the accident’s severity but wasn’t its proximate cause. It decided to modify the liability apportionment to 50% pursuant to established jurisprudence on contributory negligence.
3. Regarding the loss of earning capacity, the Supreme Court corrected the trial court’s computation, utilizing the standard 50% net earning capacity formula, leading to a recalculated award.
4. The Court upheld the awards for funeral expenses, death indemnity, and moral damages but removed the award for attorney’s fees due to lack of stipulation or statutory basis.
Doctrine: The proximate cause of an injury is that cause which, in natural and continuous sequence, unbroken by any efficient intervening cause, produces the injury, and without which the result would not have occurred. Also, in cases of contributory negligence, the Court may adjust the damages to be awarded.
Class Notes:
– Proximate Cause: The primary factor that leads to an event, particularly in tort cases, directly causing the incident’s outcome without intervention from a separate, independent cause.
– Contributory Negligence: Partial responsibility of the injured party in the incident that led to their injury, which can affect the damages awarded.
– Formula for Loss of Earning Capacity: Net Earning Capacity = 2/3 x (life expectancy – age at death) x (gross annual income – living expenses).
– Moral Damages: Awarded for psychological impact and suffering due to the defendant’s wrongful act.
– Article 2179, Civil Code: Outlines the concept of contributory negligence and its implications on the recovery of damages.
Historical Background: The evolving jurisprudence on proximate cause, contributory negligence, and computation of damages reflects the Philippine legal system’s adaptability to various factual circumstances, ensuring equitable outcomes that consider both plaintiffs’ and defendants’ actions leading to the incident.
Leave a Reply