G.R. No. 141856 , February 11, 2005
Philippine Rabbit Bus Lines, Inc., Petitioner, vs. Sinforoso F. Macalinao (substituted by his widow Clarita Macalinao) and Valentin Macalinao, Respondents.

FACTS

On August 18, 1990, respondents Sinforoso and Valentin Macalinao were driving separate tractors home along MacArthur Highway when a car hit Valentin’s tractor, immobilizing it in the middle of the road. Police investigators arrived, and Sinforoso was instructed to keep his tractor’s lights on, focused on the stalled tractor, and to flash them at approaching vehicles. He also placed lighted improvised warning devices 15 meters away. Later that rainy evening, a Philippine Rabbit bus driven by Julius Castelo approached. Castelo saw the car on the shoulder 15 meters away and swerved to the left lane, but claimed he only saw the stalled tractor 5 meters away, resulting in a collision.
Sinforoso demanded compensation from Philippine Rabbit for damages and lost income. Instead of paying, the bus company filed a complaint for damages against the Macalinaos. The Regional Trial Court dismissed the complaint and ordered Philippine Rabbit to pay actual damages and attorney’s fees, a decision affirmed by the Court of Appeals.

ISSUE

Whether the Supreme Court can review and overturn the factual findings of the lower courts, which held the petitioner’s bus driver negligent and liable for damages.

RULING

The Supreme Court denied the petition and affirmed the lower courts’ decisions. The core legal principle is that the Supreme Court is not a trier of facts. Under Rule 45 of the Rules of Court, only questions of law may be raised in a petition for review on certiorari. The findings of fact of the trial court, especially when affirmed by the Court of Appeals, are generally binding and conclusive.
The Court meticulously examined the records and found no exceptional circumstance warranting a departure from this rule. The lower courts’ conclusions were based on substantial evidence: the stalled tractor’s lights were operational and flashing, improvised warning devices were in place, the road was straight, and the bus driver had sufficient opportunity to see the hazard and slow down. The finding of gross negligence on the part of the bus driver, including excessive speed, was firmly supported. Since none of the recognized exceptions for reviewing factual findings—such as grounds entirely on speculation, grave abuse of discretion, or conclusions contradicted by evidence—were present, the Supreme Court upheld the factual determinations. The petition, being essentially a challenge to these factual findings, was therefore without merit.