G.R. No. 115024 & G.R. No. 117944. February 7, 1996.
MA. LOURDES VALENZUELA, petitioner, vs. COURT OF APPEALS, RICHARD LI and ALEXANDER COMMERCIAL, INC., respondents.

RICHARD LI, petitioner, vs. COURT OF APPEALS and LOURDES VALENZUELA, respondents.

FACTS

Petitioner Ma. Lourdes Valenzuela sustained severe injuries, including the traumatic amputation of her left leg, in a vehicular accident on June 24, 1990. While driving home, she experienced a flat tire, parked her car along the sidewalk on Aurora Boulevard with its emergency lights on, and was standing behind it when she was struck by a car driven by respondent Richard Li. Valenzuela filed an action for damages based on quasi-delict.
Li defended himself by claiming he was not negligent. He testified that an oncoming vehicle with bright lights temporarily blinded him, causing him to swerve and accidentally hit Valenzuela’s parked car, which he alleged was dark-colored, poorly lit, and protruded diagonally into the lane. He also contended Valenzuela was contributorily negligent for driving without a license. The trial court found Li grossly negligent and held him and his employer, Alexander Commercial, Inc., jointly and severally liable for damages. The Court of Appeals reversed, absolving Li of negligence and instead finding Valenzuela negligent for parking her car in a dangerous manner.

ISSUE

Whether the Court of Appeals erred in reversing the trial court’s finding of negligence on the part of respondent Richard Li and in attributing contributory negligence to petitioner Ma. Lourdes Valenzuela.

RULING

The Supreme Court reversed the Court of Appeals and reinstated the trial court’s decision with modification, holding Richard Li liable for gross negligence. The legal logic centered on the principle of res ipsa loquitur. The circumstances—a parked vehicle with emergency lights on, struck by a moving car on a straight road—spoke for themselves, creating a presumption of negligence on the part of the driver. Li failed to rebut this presumption. His claim of being blinded by oncoming lights did not absolve him; a prudent driver, faced with such a situation, should have slowed down or stopped, not swerved abruptly without ensuring the lane was clear. His failure to see the parked car indicated excessive speed or inattention.
The Court rejected the finding of contributory negligence against Valenzuela. Parking a disabled vehicle by the sidewalk with hazard lights activated is a reasonable and legal response to an emergency, not negligence. Her lack of a driver’s license was irrelevant to the cause of the accident, which resulted from Li’s failure to exercise due care. Consequently, Li, as the negligent driver, and his employer, under Article 2180 of the Civil Code, were properly held solidarily liable for damages, though the awards for unrealized profits were disallowed for lack of sufficient evidence.