G.R. No. 203081 , January 17, 2018
LINDA CACHO, ET AL., PETITIONERS, VS. GERARDO MANAHAN, DAGUPAN BUS CO., INC., AND RENATO DE VERA, RESPONDENTS.

FACTS

On June 30, 1999, a collision occurred along the national highway in Alaminos, Pangasinan, between a Nissan Sentra driven by Bismark Cacho and a bus owned by Dagupan Bus Co. and driven by Gerardo Manahan. The accident resulted in Cacho’s death and injuries to his passengers. Petitioners, Cacho’s heirs, filed a complaint for damages against Manahan, Dagupan Bus, and Renato de Vera, whose construction company had piled boulders near the road for bridge work. Petitioners alleged the bus swerved into the opposite lane to avoid the boulders, causing the collision. Respondents countered that Cacho was speeding and that the bus was fully stopped; they argued the proximate cause was either Cacho’s negligence or the construction company’s unsafe placement of the boulders.
The Regional Trial Court (RTC) found all respondents jointly and severally liable. It rejected the claim that the bus was stopped, citing physical evidence of encroachment into the opposite lane and damage inconsistent with a stationary vehicle. The RTC ruled Manahan was negligent for driving 80-100 km/h approaching a narrow bridge and failed to exercise the last clear chance to avoid the accident. It also held De Vera Construction negligent for piling boulders on the road shoulder, which posed a danger. The Court of Appeals (CA) reversed, dismissing the complaint. The CA held that the RTC’s findings were conjectural and that petitioners failed to prove respondents’ negligence was the proximate cause of the accident.

ISSUE

Whether the Court of Appeals erred in reversing the RTC’s finding of negligence on the part of respondents Manahan, Dagupan Bus Co., and De Vera, and in dismissing the complaint for damages.

RULING

Yes, the Supreme Court reversed the CA and reinstated the RTC decision with modification. The Court held that the CA erred in overturning the RTC’s factual findings, which are generally binding and entitled to great weight, especially when supported by the evidence on record. The RTC’s conclusions were based on its assessment of witness credibility, the physical evidence at the scene, and expert testimony. The Court found the RTC correctly applied the doctrine of last clear chance, holding Manahan negligent for failing to avoid the collision despite having the better opportunity to do so. As a common carrier, Dagupan Bus Co. is bound to observe extraordinary diligence; its failure, through its driver, resulted in liability.
Furthermore, the Court affirmed the finding of negligence against De Vera Construction. The presence of boulders on the road shoulder, with some having rolled onto the lane, created a hazardous condition that contributed to the accident. This constituted a failure to exercise due care in ensuring road safety during construction. The respondents were thus solidarily liable. The Supreme Court modified the award only to impose legal interest of six percent per annum on the monetary awards from the date of the RTC decision until full payment.