GR 84308; (July, 1990) (Digest)
G.R. No. 84308 July 2, 1990
HEIRS OF JUAN DACASIN, et al., petitioners, vs. THE COURT OF APPEALS, MARCELINO SUPAN y DE LA CRUZ and DAGUPAN BUS CO., INC., respondents.
FACTS
On July 24, 1978, a Valiant car owned by Juan Dacasin and driven by Danilo Garcia, carrying passengers including the petitioners’ predecessors, was traveling south on Nam Kwang Road, a through highway. Upon reaching its intersection with MacArthur Highway in Paniqui, Tarlac, it collided with a Dagupan Bus driven by respondent Marcelino Supan. The bus was traveling east on MacArthur Highway, a secondary road marked with a “Full Stop” sign and a hump approximately 16 meters before the intersection. The collision resulted in severe damage to the car, injuries to its occupants, and the death of one passenger. The bus sustained minimal damage.
The petitioners filed a civil action for damages against the bus driver and the Dagupan Bus Company. The Regional Trial Court of Dagupan City ruled in favor of the petitioners, finding the bus driver negligent for failing to stop at the through highway and awarding various damages. The Court of Appeals reversed this decision, dismissing the complaint. The petitioners elevated the case to the Supreme Court via certiorari.
ISSUE
The core issue is whether the Court of Appeals erred in reversing the trial court’s finding that the bus driver’s negligence was the proximate cause of the collision, thereby absolving the respondents of liability for damages.
RULING
The Supreme Court granted the petition, reinstated the trial court’s judgment, and held the respondents solidarily liable. The legal logic centered on the determination of proximate cause and the application of traffic right-of-way rules. The Court found the trial court’s factual findings, supported by physical evidence and the bus driver’s own admissions, to be more credible than the appellate court’s conclusions.
The Court emphasized that Nam Kwang Road was a through highway, granting its vehicles the right of way. In contrast, MacArthur Highway was a secondary road with explicit traffic controls—a “Full Stop” sign and a hump—mandating vehicles to yield. The bus driver admitted to the existence of these controls and the preferential right of way of vehicles on Nam Kwang Road. His claim that he followed two tricycles across the intersection was deemed incredible by the trial court, a finding the Supreme Court upheld. The physical evidence, particularly the damage to the right side of the car and only the front bumper of the bus, conclusively showed the bus entered the intersection and struck the car, which was lawfully traversing the through highway.
This failure to stop and yield constituted a violation of Sections 42(d) and 43(c) of the Land Transportation Code, establishing the bus driver’s reckless negligence as the proximate cause of the accident. Consequently, under Article 2180 of the Civil Code, his employer, Dagupan Bus Co., Inc., is solidarily liable for the resulting damages, the employer-employee relationship being undisputed and the employer failing to prove it exercised the diligence of a good father of a family in the selection and supervision of its driver.