GR 190022; (February, 2012) (Digest)
G.R. No. 190022 ; February 15, 2012
PHILIPPINE NATIONAL RAILWAYS CORPORATION, JAPHET ESTRANAS and BEN SAGA, Petitioners, vs. PURIFICACION VIZCARA, MARIVIC VIZCARA, CRESENCIA A. NATIVIDAD, HECTOR VIZCARA, JOEL VIZCARA and DOMINADOR ANTONIO, Respondents.
FACTS
On May 14, 2004, a passenger jeepney driven by Reynaldo Vizcara, carrying several companions, was struck by a Philippine National Railways (PNR) train operated by Japhet Estranas at a railroad crossing in Tiaong, Quezon. The collision resulted in the deaths of Reynaldo and three others, while two passengers sustained serious injuries. The crossing lacked a level crossing bar, adequate lighting, or a warning bell. The existing “Stop, Look and Listen” signage was poorly maintained, with the “Stop” sign faded and the “Listen” sign partly obscured.
The victims’ heirs and the injured survivors filed a complaint for damages against PNR and its drivers, alleging gross negligence due to the absence of adequate safety measures. Petitioners defended that the train driver exercised due diligence, blowing the horn from 400 meters away and proceeding cautiously at 25 kph after observing other vehicles stopped, but the jeepney suddenly crossed when the train was merely 10 meters away, making the collision unavoidable.
ISSUE
Whether the petitioners, PNR and its drivers, are liable for damages arising from the collision.
RULING
Yes, the petitioners are liable. The Supreme Court affirmed the findings of the lower courts, ruling that PNR was negligent. The legal logic hinges on the doctrine of res ipsa loquitur and the statutory duty of a common carrier. As a public utility operating a train, PNR is bound to observe extraordinary diligence for the safety of its passengers and the public. This duty extends to maintaining railroad crossings in a condition that ensures safety.
The proximate cause of the accident was PNR’s failure to install and maintain adequate safety devices at the crossing. The absence of a level crossing bar, bell, or proper lighting, coupled with the poorly maintained signage, constituted a breach of its duty. This failure created a hazardous condition that directly contributed to the collision. The defense of sudden entry by the jeepney does not absolve PNR, as the lack of sufficient warning mechanisms prevented the driver from being properly alerted to the train’s approach. The train crew’s actions, while claimed to be careful, do not offset the corporation’s primary negligence in ensuring the crossing’s safety. Consequently, PNR is solidarily liable with its employees for the resulting damages, as modified by the Court of Appeals.