MARK ERQUIZA LAZA AND DANILO C. AGPOON, PETITIONERS, VS. STANDARD INSURANCE CO., INCORPORATED, RESPONDENT.

Laza versus Standard Insurance

The Case

This is a petition for review on certiorari brought by Mark Erquiza Laza and Danilo Agpoon against Standard Insurance Company, Incorporated. The case arises from a claim for recovery of sum of money based on quasi-delict, where the insurer, having paid its insured for property damage, sought reimbursement from the alleged tortfeasors as subrogee. The case matters because it clarifies the boundaries of the Court's review power over factual findings in negligence cases, and reaffirms the requisites for liability under quasi-delict, including the doctrine of vicarious liability of an employer for the negligent acts of its employee.

Procedural History

Standard Insurance filed a complaint for recovery of sum of money based on quasi-delict before the Metropolitan Trial Court. The trial court dismissed the complaint for lack of merit, finding that Standard Insurance failed to prove Agpoon's negligence. On appeal, the Regional Trial Court reversed the trial court's decision and ruled in favor of Standard Insurance, ordering Laza and Agpoon to pay jointly and severally the amount of 270,509.42 pesos, plus legal interest, attorney's fees, and costs of suit. Laza and Agpoon appealed to the Court of Appeals, which affirmed the Regional Trial Court's ruling. Their motion for reconsideration was denied. They then filed the present petition for review on certiorari before the Supreme Court, raising questions on the negligence of the parties and alleged violations of traffic regulations.

Facts

On November 6, 2014, a vehicular accident occurred along the National Highway of Barangay Urayong, Bauang, La Union. A Honda CR-V owned and driven by Peter Paul Nang collided with a Toyota Innova driven by Danilo Agpoon, which was registered to Mark Erquiza Laza. Standard Insurance was the insurer of Nang's CR-V. After the accident, Standard Insurance paid Nang's property damage claim in the amount of 270,509.42 pesos and, as subrogee, demanded reimbursement from Laza and Agpoon. When they refused to pay, Standard Insurance filed the complaint.

The parties presented conflicting versions of the accident. Laza and Agpoon claimed that Nang made a sudden U-turn across the road without waiting for his turn, forcing Agpoon to swerve to the right shoulder to avoid a collision, but the left side of the Innova still hit the right front portion of the CR-V. Standard Insurance, on the other hand, presented evidence that Nang had signaled his intention to turn left, that a Nissan Sentra on the opposite lane had blinked its headlights to give way, and that Agpoon, overtaking the Sentra on the right shoulder at accelerated speed, hit the CR-V. Agpoon allegedly admitted to overtaking on the shoulder both at the scene and at the police station.

Issues

• Whether or not the Court of Appeals erred in sustaining the Regional Trial Court's decision in favor of Standard Insurance.
• Whether or not the issues raised by the petitioners, particularly on who was negligent and whether there was a violation of Republic Act Number 4136, are factual in nature and beyond the scope of a petition for review on certiorari.

Applicable Provisions

Article 2176 of the Civil Code, which governs civil actions based on quasi-delicts, provides:

Whoever by act or omission causes damage to another, there being fault or negligence, is obliged to pay for the damage done. Such fault or negligence, if there is no pre-existing contractual relation between the parties, is called a quasi-delict and is governed by the provisions of this Chapter.

This provision establishes the basis for liability in the present case, requiring the concurrence of damage, fault or negligence, and proximate cause.

Article 2180 of the Civil Code, which establishes vicarious liability of employers, provides the basis for holding Laza liable for the negligent acts of his employee Agpoon.

Ruling

The Supreme Court denied the petition and affirmed the rulings of the lower courts. The Court held that the issues raised by the petitioners were factual in nature, and that the Court is not a trier of facts. Under Rule 45, Section 1 of the Rules of Court, a petition before the Court must only raise questions of law. The Court found that the petitioners failed to show any applicable exception to this general rule, nor did they establish grave abuse of discretion on the part of the Court of Appeals.

On the merits, the Court agreed with the lower courts' finding that Standard Insurance substantially proved Agpoon's negligence. The Court quoted the definition of negligence:

Negligence is defined as the failure to observe for the protection of the interests of another person that degree of care, precaution, and vigilance which the circumstances justly demand, by reason of which such other person suffers injury. The test to determine the existence of negligence in a particular case may be stated as follows: Did the defendant in the performance of the alleged negligent act use reasonable care and caution which an ordinary person would have used in the same situation? If not, then he is guilty of negligence.

The Court found that all requisites for quasi-delict liability were present: the CR-V sustained damages, Agpoon was at fault and negligent as he admitted to overtaking on the left and swerving to the right shoulder, and his negligence was the proximate cause of the damage. The Court also rejected the petitioners' claim that Nang violated traffic regulations under Sections 42(a) and 44(a) of Republic Act Number 4136, adopting the Court of Appeals' finding that Nang had already occupied a substantial portion of the opposite lane when making his turn, and that the Sentra had given way to him.

Doctrine

• In a petition for review on certiorari under Rule 45, only questions of law may be raised; the Supreme Court is not a trier of facts, and factual findings of the lower courts, when supported by evidence, are binding and conclusive.
• To sustain a claim based on quasi-delict under Article 2176 of the Civil Code, the following requisites must concur: damage suffered by the plaintiff, fault or negligence of the defendant, and proximate cause connecting the fault or negligence to the damage.
• Negligence is the failure to observe for the protection of the interests of another person that degree of care, precaution, and vigilance which the circumstances justly demand, tested against the standard of an ordinary person in the same situation.
• An employer is vicariously liable for the negligent acts of its employee under Article 2180 of the Civil Code.

Disposition

The Supreme Court denied the petition and affirmed the Decision of the Court of Appeals dated May 10, 2024 and its Resolution dated April 4, 2025, ordering Laza and Agpoon to pay Standard Insurance the amount of 270,509.42 pesos as actual damages, plus attorney's fees, interest, and costs.

Remember This

The single line worth memorizing is that the Supreme Court is not a trier of facts, and a petition under Rule 45 must raise only questions of law. Examiners like to use this case to test your understanding of the requisites of quasi-delict liability under Article 2176 and the vicarious liability of employers under Article 2180, as well as the procedural limits of a petition for review on certiorari.