G.R. No. 118441-42 January 18, 2000
ARMANDO JOSE y PAZ and MANILA CENTRAL BUS LINES (MCL), represented by its General Manager MR. DANILO T. DE DIOS, petitioners, vs. COURT OF APPEALS, ROMMEL ABRAHAM, represented by his father FELIXBERTO ABRAHAM, JOSE MACARUBO and MERCEDES MACARUBO, respondents.

FACTS

On February 22, 1985, a bus owned by Metro Manila Transit Corporation but operated by petitioner Manila Central Bus Lines (MCL) and driven by petitioner Armando Jose collided with a Ford Escort driven by John Macarubo on MacArthur Highway in Valenzuela. The collision resulted in the death of Macarubo and serious injuries to his passenger, respondent Rommel Abraham, including the loss of his left eye. Abraham and the parents of the deceased Macarubo filed separate civil cases for damages against MCL and Jose. The trial court dismissed the complaints, finding that the Ford Escort, due to its driver’s fatigue from a party and all-night car repair, had crossed into the opposing lane while overtaking and struck the bus, which was in its proper lane. The court also ruled favorably on MCL’s third-party complaint against the car’s registered owner, Juanita Macarubo.
The Court of Appeals reversed the trial court’s decision. It held that the trial court erred in disregarding Abraham’s testimony that the bus was overtaking and encroached into their lane, in relying on photographs taken an hour post-accident, and in finding that MCL exercised due diligence in the selection and supervision of its driver. The CA ordered petitioners to pay damages jointly and severally. Petitioners sought review by the Supreme Court.

ISSUE

The primary issue is whether the Court of Appeals erred in reversing the trial court’s factual findings and conclusions on the determination of negligence and liability for the vehicular accident.

RULING

The Supreme Court granted the petition and reinstated the trial court’s decision, dismissing the complaints against the petitioners. The Court emphasized that factual findings of the trial court, especially when affirmed by the CA, are generally binding. However, in this instance, the Court found that the CA improperly substituted its own assessment of the evidence. The trial court’s conclusion that the Ford Escort was at fault was based on a holistic evaluation of evidence, including the physical damage to the vehicles and the probable condition of its driver, John Macarubo. The Court noted that the CA’s reliance on Abraham’s lone testimony was misplaced, as it was uncorroborated and contradicted by the physical evidence analyzed by the trial court.
Regarding employer liability, the Court found that MCL successfully rebutted the presumption of negligence in the selection and supervision of its driver, Armando Jose, by presenting evidence of his valid professional driver’s license, training seminars, and a clean driving record. Consequently, MCL could not be held vicariously liable under Article 2180 of the Civil Code. Finally, the Court dismissed MCL’s third-party complaint against Juanita Macarubo, as MCL failed to prove that John Macarubo was her employee or that she was liable for his negligence. The complaints against the petitioners were therefore dismissed.