Baliwag Transit, Inc. v. CA

G.R. No. 116624 (September 20, 1996)

Facts:

Mario Dionisio was employed as a mechanic and was the sole breadwinner for his family, which included his wife, Divina, and their two minor children, Mark Angelo and Ma. Liza. On November 2, 1990, while working on the brake system of Baliwag Transit Bus No. 117, driven by Juanito Fidel, a tragic accident occurred. After instructing Dionisio to inform the headman about the bus needing repairs, Fidel left the bus to have it refueled. Upon returning, he sat in the driver's seat, causing the bus to move unexpectedly. The bus rolled over Dionisio, who was working underneath, resulting in severe injuries that led to his death on November 6, 1990.

Following Dionisio's death, his family filed a complaint for damages against Baliwag Transit, Inc. and Juanito Fidel in the Regional Trial Court of Quezon City. The trial court ruled in favor of the family, awarding them various damages, including death indemnity and funeral expenses. The family appealed to the Court of Appeals, which modified the trial court's decision, significantly increasing the damages awarded, including compensation for loss of earning capacity and moral damages.

Baliwag Transit and Fidel subsequently filed a petition for review, arguing that the Court of Appeals erred in its decision by not considering the contributory negligence of Dionisio and that the damages awarded were excessive and unsupported by evidence.

Legal Issues:

1. Was there contributory negligence on the part of Mario Dionisio that should mitigate the liability of Baliwag Transit and Juanito Fidel?
2. Were the damages awarded by the Court of Appeals reasonable and supported by the evidence presented?

Arguments:

Petitioners' Arguments:

• The petitioners contended that Dionisio exhibited contributory negligence by failing to take necessary precautions while working on the bus's brake system, which contributed to the accident.
• They argued that the increase in damages awarded by the Court of Appeals was unreasonable and not substantiated by the evidence presented during the trial.

Respondents' Arguments:

• The respondents maintained that the proximate cause of Dionisio's death was the negligence of Juanito Fidel, who failed to ensure the bus was safely parked and did not take precautions to prevent it from moving.
• They asserted that the damages awarded were justified based on the loss of earning capacity, moral damages, and other compensatory factors, as Dionisio was the family's sole provider.

Court's Decision and Legal Reasoning:

The Supreme Court upheld the decision of the Court of Appeals, emphasizing that the primary cause of the accident was the negligence of Juanito Fidel. The Court found that Fidel had a duty to ensure the safety of the bus while it was being repaired and failed to take necessary precautions, such as properly securing the vehicle. The Court ruled that the employer, Baliwag Transit, was also liable for the actions of its employee under the principles of vicarious liability as outlined in Articles 2176 and 2180 of the Civil Code.

The Court also addressed the issue of damages, affirming that the awards for loss of earning capacity, moral damages, and other compensatory damages were reasonable. The Court provided a detailed computation of the loss of earning capacity, taking into account Dionisio's age, income, and family responsibilities. The Court noted that the heirs suffered significant mental anguish due to the sudden loss of their breadwinner, justifying the award for moral damages. Additionally, the Court found that exemplary damages were warranted due to the gross negligence exhibited by Fidel.

Significant Legal Principles Established:

1. Vicarious Liability: Employers are liable for the negligent acts of their employees performed within the scope of their employment, unless they can prove they exercised due diligence in the selection and supervision of the employee.
2. Contributory Negligence: The presence of contributory negligence does not absolve the employer from liability but may affect the amount of damages awarded.
3. Damages Calculation: The computation of loss of earning capacity must consider the deceased's life expectancy, income, and family obligations, and moral damages can be awarded for the mental anguish suffered by the heirs.