GR 152040; (March, 2006) (Digest)
G.R. No. 152040. March 31, 2006.
MARIKINA AUTO LINE TRANSPORT CORPORATION and FREDDIE L. SUELTO, Petitioners, vs. PEOPLE OF THE PHILIPPINES and ERLINDA V. VALDELLON, Respondents.
FACTS
Petitioner Freddie Suelto, a driver for Marikina Auto Line Transport Corporation (MALTC), was driving a passenger bus along Kamias Road, Quezon City, on October 3, 1992. The bus swerved to the right and struck the terrace of a commercial apartment owned by respondent Erlinda Valdellon, causing significant structural damage. Valdellon demanded payment for repairs, but the petitioners offered only a P30,000 settlement, which she refused. Subsequently, Valdellon filed a criminal complaint for reckless imprudence resulting in damage to property against Suelto and a separate civil case for damages against both Suelto and MALTC.
During trial, Suelto claimed he swerved to avoid a jeepney that suddenly crossed his path. The trial court, however, found him guilty of reckless imprudence. It ordered him to pay a fine and, jointly and severally with MALTC, to pay Valdellon actual damages of P100,000 and exemplary damages of P20,000. The Court of Appeals affirmed this decision. The petitioners elevated the case to the Supreme Court, contesting the conviction and the awarded damages.
ISSUE
The primary issues were: (1) whether Suelto was guilty of reckless imprudence, and (2) whether the awarded actual damages of P100,000 was proper based on the evidence presented.
RULING
The Supreme Court affirmed Suelto’s conviction but modified the damages. On criminal liability, the Court upheld the findings of the lower courts, which gave greater weight to the prosecution’s evidence over Suelto’s claim of a sudden emergency. His failure to exercise the necessary precaution constituted negligence.
Regarding damages, the Court ruled that the award of actual damages must be based on competent proof of the actual loss suffered. The trial court’s award of P100,000 was not supported by the evidence. The only competent proof submitted was a receipt for P35,000 for partial repairs and an architect’s estimate of P55,000 for the complete restoration of the damaged terrace, as presented by the defense. The Court held that the lower estimate of P55,000, which was not contradicted by other detailed estimates, constituted the best evidence of the actual loss. Therefore, the actual damages were reduced to P55,000. The award of P20,000 in exemplary damages was deemed reasonable and was sustained. The fine imposed on Suelto was also adjusted to P55,000 to correspond with the proven actual damages.