G.R. No. 184905; August 28, 2009
Lambert S. Ramos, Petitioner, vs. C.O.L. Realty Corporation, Respondent.

FACTS

On March 8, 2004, a collision occurred in Quezon City between a Toyota Altis owned by respondent C.O.L. Realty Corporation, driven by Aquilino Larin, and a Ford Expedition owned by petitioner Lambert Ramos, driven by Rodel Ilustrisimo. Respondent’s car, carrying a passenger who was injured, was crossing Katipunan Avenue from Rajah Matanda Street when it was struck on the right rear by petitioner’s vehicle. Respondent filed a complaint for damages based on quasi-delict against petitioner, alleging his driver’s negligence caused the accident. Petitioner denied liability, asserting respondent’s driver was solely negligent for crossing a prohibited intersection marked by barricades due to ongoing construction.
The Metropolitan Trial Court (MeTC) dismissed the complaint, finding no liability on petitioner’s part. The Regional Trial Court (RTC) affirmed this dismissal. The Court of Appeals, however, modified the ruling. It found both drivers contributorily negligent: Aquilino for violating an MMDA prohibition against crossing that intersection, and Rodel for driving at high speed in a busy construction area. The appellate court held petitioner solidarily liable with his driver and ordered them to pay respondent P51,994.80 as actual damages.

ISSUE

Whether petitioner Lambert Ramos can be held solidarily liable for damages arising from the vehicular accident.

RULING

The Supreme Court granted the petition and reversed the Court of Appeals. The Court held that Aquilino Larin’s negligence was the proximate cause of the accident. The MMDA certification conclusively established that crossing Katipunan Avenue from Rajah Matanda Street was prohibited since January 2004 due to road construction, and barricades were in place. By crossing through a broken portion of these barricades, Aquilino committed a reckless violation of traffic rules. This act created an immediate and foreseeable danger on a busy, obstructed thoroughfare.
Applying Article 2179 of the Civil Code, the Court ruled that when a plaintiff’s own negligence is the immediate and proximate cause of the injury, no recovery of damages is permitted. The contributory negligence of petitioner’s driver, Rodel, while noted, was irrelevant to establishing respondent’s cause of action. Such contributory negligence could only serve to mitigate damages if petitioner himself were claiming injury from respondent; it could not overcome or negate the proximate causation by Aquilino’s recklessness. Consequently, respondent’s claim for damages failed, and the RTC decision dismissing the complaint was reinstated.