_Mauricio Manliclic and Philippine Rabbit Bus Lines, Inc. v. Modesto Calaunan_
**Facts:**
On July 12, 1988, around 6:00-7:00 AM, Modesto Calaunan and his driver Marcelo Mendoza were traveling from Pangasinan to Manila in Calaunan’s owner-type jeep. Simultaneously, Mauricio Manliclic, employed by Philippine Rabbit Bus Lines, Inc., was driving Bus No. 353 from Concepcion, Tarlac to Manila. At Kilometer 40 on the North Luzon Expressway, Barangay Lalangan, Plaridel, Bulacan, the bus collided with Calaunan’s jeep from behind, causing the jeep to veer off the road into a ditch and sustain extensive damage. Calaunan suffered minor injuries and was hospitalized.
A criminal case for Reckless Imprudence Resulting in Damage to Property with Physical Injuries was filed against Manliclic in the RTC of Malolos, Bulacan. Subsequently, Calaunan filed a civil case for damages against Manliclic and PRBLI in the RTC of Dagupan City. During the civil case hearings, various testimonies and evidence presented in the criminal case were admitted, including testimony transcripts from witnesses Calaunan, Mendoza, and another witness, Fernando Ramos, who were unavailable during the civil trial.
The trial court rendered a decision in favor of Calaunan, awarding actual, moral, exemplary damages, and attorney’s fees. PRBLI’s appeal to the Court of Appeals was denied, affirming the trial court’s decision.
**Issues:**
1. Whether the Court of Appeals erred in affirming the RTC’s admission of the testimonies and documents from the criminal case.
2. Whether the Court of Appeals erred in affirming the trial court’s reliance on Calaunan’s version of the event.
3. Whether the Court of Appeals erred in affirming the trial court’s disregard of PRBLI’s defense of exercising due diligence in the selection and supervision of its employees.
4. Whether the Court of Appeals erred in affirming the award of damages and attorney’s fees.
**Court’s Decision:**
1. **Admissibility of Testimonies and Documents:**
The Court ruled that while Section 47, Rule 130 of the Rules of Court was not strictly adhered to because PRBLI was not a party in the criminal case, the petitioner waived any objections by failing to object when the evidence was offered. This lack of timely objection rendered the testimonies admissible despite the technical noncompliance.
2. **Credibility of Versions:**
The Court upheld the factual findings of the trial court, emphasizing that the inconsistencies in Manliclic’s statements, coupled with the logical coherence and corroboration of Calaunan’s version by another witness, supported the conclusion that the collision was caused by Manliclic’s negligence.
3. **Due Diligence by PRBLI:**
The Court reaffirmed that PRBLI failed to demonstrate sufficient evidence of exercising due diligence in supervising its employees. It stated that mere presence of post-accident investigators did not constitute continuous and effective supervision.
4. **Award of Damages:**
The Court modified the damages awarded:
– Reduced moral damages to P50,000.00.
– Reduced exemplary damages to P50,000.00.
– Affirmed the award of actual damages and attorney’s fees.
**Doctrine:**
The case elaborates the principles governing the admissibility of prior testimonies under Rule 130 of the Rules of Court, the presumption of employer negligence under Article 2180 of the Civil Code, and civil liability arising from quasi-delicts independent of acquittal in a related criminal case.
**Class Notes:**
– **Quasi-delict:** Defined in Article 2176 of the Civil Code. Liability arising from negligence not based on contractual relations.
– **Negligence of Employee:** Presumption of employer’s negligence in the selection and supervision of employees if an employee’s negligence causes damage.
– **Rule 130, Section 47:** Conditions for the admissibility of a witness’s testimony from a previous judicial proceeding.
– **Employer’s Liability:** Obligation under Article 2180 requires employers to show proof of due diligence in the selection and supervision of employees.
– **Due Diligence Requirements:** Must include effective recruitment, regular supervision, and enforcement of operational safety standards.
**Historical Background:**
This case forms part of judicial interpretation of employer liability and the admissibility of testimonies in subsequent civil actions based on the same act. It clarifies the separateness of civil liability arising from a quasi-delict from that arising from a criminal act and the procedural standards for admitting prior testimonies.
Leave a Reply