G.R. No. 172200 ; July 6, 2010
THE HEIRS OF REDENTOR COMPLETO and ELPIDIO ABIAD, Petitioners, vs. SGT. AMANDO C. ALBAYDA, JR., Respondent.

FACTS

Respondent Amando Albayda, a military sergeant, filed a civil case for damages against petitioners Redentor Completo, a taxi driver, and the taxi owner, Elpidio Abiad. Albayda alleged that on August 27, 1997, while he was riding a bicycle along 11th Street inside Villamor Air Base, the taxi driven by Completo sideswiped and bumped him at the intersection of 8th and 11th Streets. The incident caused serious injuries, including a fractured left knee, requiring multiple hospital confinements totaling approximately seven months. Albayda claimed the accident was due to Completo’s negligence, as the taxi was speeding. He sought reimbursement for medical expenses, moral damages for his suffering and his wife’s subsequent abandonment, exemplary damages, and attorney’s fees.
Completo countered that he was driving carefully at a reduced speed of 20 kph. He asserted that Albayda was the negligent party, riding his bicycle at a very high speed, which caused him to lose control and hit the rear right side of the taxi. Completo argued that the damage to the taxi’s door was from the impact of Albayda’s body, not from a sideswipe by the taxi. He maintained that Albayda had no cause of action and filed the suit merely to harass them and unjustly enrich himself.

ISSUE

Whether the petitioners are liable for damages arising from quasi-delict based on the evidence presented.

RULING

The Supreme Court affirmed the lower courts’ findings, ruling petitioners solidarily liable for damages. The Court upheld the factual conclusions of the trial court and the Court of Appeals, which found Completo negligent. The legal logic rests on the principle that factual findings of lower courts, when supported by evidence, are binding on the Supreme Court. The trial court found the testimony of eyewitness Michael Navarro credible. Navarro testified that the taxi was running at an unusual speed and hit the bicycle at the intersection. This testimony, coupled with the medical evidence of Albayda’s severe injuries caused by a “hard impact,” sufficiently established Completo’s negligence as the proximate cause of the accident.
The Court rejected petitioners’ defense of Albayda’s contributory negligence, as they failed to present clear and convincing evidence to support this claim. The employer, Abiad, was held solidarily liable under Article 2180 of the Civil Code for the negligent acts of his employee, Completo, who was driving in the course of employment. The awarded damages were deemed proper: actual damages for proven medical expenses, moral damages for the physical suffering and mental anguish (aggravated by his wife’s abandonment), and temperate damages for unreceipted but necessary medical costs. Exemplary damages were also justified due to Completo’s reckless disregard for the safety of others. The decision underscores that liability for quasi-delict is imposed upon one who, by act or omission, causes damage to another through fault or negligence.