### Facts:
On the morning of October 8, 1959, Lolita de Jesus, the 20-year-old daughter of Valentin de Jesus and wife of Manolo Tolentino, was a passenger on a bus operated by La Mallorca and Pampanga Bus Company, Inc. (La Mallorca-Pambusco). While traveling through a barrio in Marilao, Bulacan, the bus experienced a sudden blowout of its left front tire. This caused the driver to lose control of the vehicle, leading to a head-on collision with a freight truck traveling in the opposite direction. The collision resulted in the death of Lolita de Jesus.
Subsequently, Valentin de Jesus and Manolo Tolentino filed a civil suit against La Mallorca-Pambusco in the Court of First Instance (CFI) of Bulacan, alleging negligence and seeking damages. The CFI ruled in favor of the plaintiffs, awarding them P2,132.50 for actual damages, P14,400.00 for compensatory damages, P10,000.00 each in moral damages, and P3,000.00 as counsel fees.
La Mallorca-Pambusco appealed the decision to the Court of Appeals, which affirmed the decision of the CFI. Discontent with the appellate court’s ruling, La Mallorca-Pambusco then filed a petition for certiorari before the Supreme Court.
### Issues:
1. Whether the tire blowout that led to the collision can be considered a fortuitous event (caso fortuito) thereby exempting La Mallorca-Pambusco from liability due to negligence.
2. Whether La Mallorca-Pambusco can be held liable for moral damages due to the death of a passenger caused by the breach of contract of a common carrier.
### Court’s Decision:
**Issue 1: Tire Blowout as Fortuitous Event**
– La Mallorca-Pambusco argued that the tire blowout was a fortuitous event and did not give rise to liability for negligence.
– However, the Supreme Court noted key findings by the Court of Appeals, which stated that the tire blowout was caused by a mechanical defect: the inner tube of the left front tire was pressed between the inner circle of the wheel and the rim, which had slipped out of place.
– This defect could have been discovered through a more rigorous check-up before the bus commenced its journey.
– Additionally, it was established that the bus was traveling at a high speed prior to the blowout and that the tire which exploded was not in optimal condition.
– This led the Court to conclude that the plea of caso fortuito was untenable and that La Mallorca-Pambusco was liable for negligence due to its failure to properly maintain the bus and ensure its safe condition.
**Issue 2: Liability for Moral Damages**
– La Mallorca-Pambusco contended against the award of moral damages.
– The Supreme Court affirmed the ruling, citing Article 1764 in relation to Article 2206 of the Civil Code.
– These provisions state that moral damages are recoverable when a passenger’s death is caused by the breach of contract by a common carrier.
– The Court upheld the amount awarded for moral damages, reiterating that such damages are recoverable under Philippine jurisprudence in similar cases.
### Doctrine:
– **Mechanical Defect and Negligence:** A mechanical defect that can be discovered through thorough inspection does not constitute a fortuitous event and does not absolve a common carrier of liability for negligence.
– **Moral Damages in Breach of Contract by Common Carrier:** Following Article 1764 in relation to Article 2206 of the Civil Code, moral damages are recoverable for the death of a passenger due to the breach of contract by a common carrier.
### Class Notes:
– **Key Legal Concepts and Statutes:**
1. **Caso Fortuito (Fortuitous Event):** An event which cannot be foreseen or resisted.
2. **Common Carrier Liability:** Under Philippine law, common carriers are bound to observe extraordinary diligence in the transportation of passengers (Civil Code).
3. **Mechanical Defect:** Defects that could be discovered during regular maintenance inspections warrant the liability of the carrier.
4. **Moral Damages:** Article 1764 in relation to Article 2206 of the Civil Code allows for recovery of moral damages for the death of a passenger caused by a carrier’s breach of contract.
– **Application and Interpretation:**
– The courts demanded rigorous maintenance and safety checks as part of the carrier’s duty of extraordinary diligence.
– The award of moral damages in cases of breach of contract by common carriers reinforces the protection afforded to passengers under Philippine law.
### Historical Background:
This case is set in the context of the Philippines’ evolving legal framework concerning the responsibility and accountability of common carriers. In the mid-20th century, public transportation was becoming more widespread, leading to stricter regulations and heightened legal standards to ensure passenger safety and promote diligent business practices among transport operators. The Court’s decision reflects jurisprudential evolution towards robust consumer protection and heightened accountability for common carriers.
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