POLYTECHNIC UNIVERSITY OF THE PHILIPPINES
COLLEGE OF LAW
OBLIGATIONS AND CONTRACTS
SECOND SEMESTER AY 2023 - 2024
NAME: Irlandez, Ma. Christine M.
SECTION:
CASE DIGEST
TITLE OF THE CASE: Guillang v. Bedania, G.R. No. 162987, Ma y 21, 2009
GR # AND DATE: G.R. No. 162987, Ma y 21, 2009
PONENTE: CARPIO, J
CASE DOCTRINE Article 2176 of thequasi-delict. To sustain a claim based on quasi-delict,
the following requisites must concur: (a) damage suffered by the plaintiff;
(b) fault or negligence of defendant; and (c) connection of cause and effect
between the fault or negligence of defendant and the damage incurred by
the plaintiff.
Court based its decision on the principle of negligence in quasi-delict
cases.
Court held the driver of the truck negligent in executing a sudden U-turn
without signal lights, posing a serious risk to oncoming motorists.
Court emphasized that the truck encroached upon the car's lane when it
made the U-turn, making the truck liable for the collision.
Court held the owner of the truck liable for damages as he failed to prove
that he exercised all the diligence of a good father of a family in the
selection and supervision of his employees.
Court awarded various damages to the plaintiffs, including indemnity for
death, moral damages, hospitalization expenses, and attorney's fees.
FACTS This case involves a petition for review of a decision made by the Court of
Appeals in CA-G.R. CV No. 69289. The decision set aside the previous decision
made by the Regional Trial Court in favor of the petitioners. The petitioners filed
the complaint for damages based on quasi-delict against the respondents. The
trial court found the respondents grossly negligent and held them liable for
damages. The Court of Appeals, however, reversed the decision and dismissed
the complaint.
On October 25, 1994, petitioner Genaro M. Guillang was driving his car along
Emilio Aguinaldo Highway in Cavite. At the same time, respondent Rodolfo A.
Bedania was driving a truck towards Tagaytay City. Bedania made a U-turn on
the highway and Genaro's car collided with the truck. As a result, all the
passengers of the car were rushed to the hospital for treatment. One of the
passengers, Antero Guillang, later died due to the injuries sustained from the
collision. The petitioners filed a complaint for damages against the respondents.
The Ruling of the Regional Trial Court
The trial court found Bedania grossly negligent for making a sudden U-turn
without regard to traffic rules and the safety of other motorists. The court also
held de Silva, the owner of the truck, grossly negligent in the selection and
supervision of his driver. The trial court ordered the respondents to pay damages
to the petitioners.
The Ruling of the Court of Appeals
The Court of Appeals reversed the trial court's decision and dismissed the
complaint. The court concluded that the collision was caused by Genaro's
negligence for failing to stop the car despite seeing that Bedania was making a U-
turn. The court also dismissed the testimonies of the witnesses, stating that they
were contrary to human observation and experience.
ISSUE/S: Who is liable for the damages suffered by the plaintiffs?
RULING: The Supreme Court, in reviewing the case, found that the Court of Appeals'
conclusion that Genaro was negligent was not supported by the evidence. The
court pointed out inconsistencies in the testimony of a police traffic investigator
and concluded that Bedania was the one who was negligent for making a sudden
U-turn without signal lights. The court also found that de Silva, as Bedania's
employer, was liable for damages due to his failure to exercise due diligence in
the selection and supervision of his employees.
The court awarded damages to the petitioners, including indemnity for death,
moral damages, hospitalization expenses, and attorney's fees. The court modified
the amount of funeral and burial expenses awarded by the trial court and
reduced the amount of moral damages. The court affirmed the trial court's award
of exemplary damages and attorney's fees.
WHEREFORE, we REVERSE the 3 June 2003 Decision and 23 March 2004
Resolution of the Court of Appeals in CA-G.R. CV No. 69289. We REINSTATE
with MODIFICATIONS the 5 December 2000 Decision of the Regional Trial
Court, Branch 30, Manila. We ORDER Rodolfo Bedania and Rodolfo de Silva,
jointly and severally, to pay the following amounts:
1. Funeral and Burial Expenses of P135,000 to the heirs of Antero Guillang;
HAISEa
2. Hospitalization Expenses of P27,000.98 to the heirs of Antero Guillang,
P10,881.60 to Alvin Llanillo, P5,436.77 to Jose Dignadice, and P300 to Genaro
Guillang; and
3. Moral damages of P30,000 each to Alvin Llanillo, Jose Dignadice, and Genaro
Guillang.
SO ORDERED.
