ORIX METRO LEASING AND FINANCE CORPORATION vs.

MANGALINAO, G.R. No. 174089. JANUARY 25, 2012

FACTS:
This a case of multiple-vehicle collision in North Luzon Expressway
(NLEX) resulting in the death of all the passengers in one vehicle, including
the Mangalinao spouses and a sibling of the surviving orphaned minor
heirs.
An action for damages based on quasi delict was filed by the minor children
of the Mangalinao spouses through their legal guardian against the
registered owners and drivers of the two 10-wheeler trucks that collided
with their parents Nissan Pathfinder. The children imputed recklessness,
negligence, and imprudence on the truck drivers for the deaths of their
sister and parents; while they hold Sonny and Orix equally liable for failing
to exercise the diligence of a good father of a family in the selection and
supervision of their respective drivers.

ISSUE:
Whether or not the defendants are jointly and severally liable.

RULING:
The finding of negligence of petitioners as found by the lower courts
is binding. Negligence and proximate cause are factual issues. Settled is the
rule that this Court is not a trier of facts, and the concurrence of the
findings of fact of the courts below are conclusive.
Orix as the operator on record of the Fuso Truck is liable to the heirs
of the victims of the mishap. Orix cannot point fingers at the alleged real
owner to exculpate itself from vicarious liability under Article 2180 of the
Civil Code. Regardless of whoever Orix claims to be the actual owner of the
Fuso by reason of a contract of sale, it is nevertheless primarily liable for
the damages or injury the truck registered under it have caused. Besides,
the registered owners have a right to be indemnified by the real or actual
owner of the amount that they may be required to pay as damage for the
injury caused to the plaintiff, which Orix rightfully acknowledged by filing a
third-party complaint against the owner of the Fuso, Manuel. Moral
damages, it must be stressed, are not intended to enrich plaintiff at the
expense of the defendant. They are awarded to enable the injured party to
obtain means, diversions, or amusements that will serve to alleviate the
moral suffering he/she had undergone due to the other partys culpable
action and must, perforce, be proportional to the suffering inflicted.

SANITARY STEAM LAUNDRY, INC., vs. THE COURT OF APPEALS,

G.R. No. 119092. DECEMBER 10, 1998

FACTS:
This case involves a collision between a Mercedes Benz panel truck of
petitioner Sanitary Steam Laundry and a Cimarron which caused the death
of three persons and the injuries of several others. The accident took place
at the Aguinaldo Highway in Imus, Cavite on August 31, 1980. The
passengers of the Cimarron were mostly employees of the Project
Management Consultants, Inc. (PMCI). The Cimarron was owned by
Salvador Salenga. Driving the vehicle was Rolando Hernandez. It appears
that at about 8:00 p.m., as it was traveling along Aguinaldo Highway in
Imus, Cavite on its way back to Manila, the Cimarron was hit on its front
portion by petitioners panel truck which was traveling in the opposite
direction. The driver, Herman Hernandez, claimed that a jeepney in front of
him suddenly stopped. He said he stepped on the brakes to avoid hitting the
jeepney and that this caused his vehicle to swerve to the left and encroach
on a portion of the opposite lane. As a result, his panel truck collided with
the Cimarron on the north-bound lane. The driver of the Cimarron, Rolando
Hernandez, and two of his passengers, namely, Jason Bernabe and Dalmacio
Salunoy, died. Several of the other passengers of the Cimarron were injured
and taken to various hospitals.

ISSUE:
Whether the driver of the Cimarron was guilty of contributory
negligence and, therefore, the liability of the petitioner should be mitigated,
if not totally extinguished.

RULING:
No. It has not been shown how the alleged negligence of the
Cimarron driver contributed to the collision between the vehicles. Indeed,
petitioner has the burden of showing a causal connection between the
injury received and the violation of the Land Transportation and Traffic
Code. He must show that the violation of the statute was the proximate or
legal cause of the injury or that it substantially contributed thereto.
Negligence, consisting in whole or in part, of violation of law, like any other
negligence, is without legal consequence unless it is a contributing cause of
the injury. Petitioner says that driving an overloaded vehicle with only one
functioning headlight during nighttime certainly increases the risk of
accident, that because the Cimarron had only one headlight, there was
decreased visibility, and that the fact that the vehicle was overloaded and
its front seat overcrowded decreased [its] maneuverability. However,
mere allegations such as these are not sufficient to discharge its burden of
proving clearly that such alleged negligence was the contributing cause of
the injury.
AMADOR CORPUZ AND ROMEO GONZALES vs. EDISON LUGUE AND
CATHERINE BALUYOT, G.R. No. 137772. JULY 29, 2005

FACTS:
On 14 September 1984, at around 7:15 in the morning, while an
Isuzu KC-20 passenger jeep (KC-20), then being driven by Jimmy Basilio,
was traversing the right side of the Roman Highway in Barangay Pias,
Orion, Bataan, it collided with a tanker truck driven by Gerardo Lim,
which was then moving from the right shoulder of the highway. As a
consequence of the accident, passengers of the KC-20, including
respondent Lugue, suffered physical injuries. Respondent Lugue then
filed an action for damages arising from the vehicular incident before the
Balanga, Bataan RTC, Branch 2, against herein petitioners Amador
Corpuz and Romeo Gonzales, owner and driver of the minibus,
respectively, and Oscar Jaring and Gerardo Lim, owner and driver of the
tanker truck, respectively. Therein defendants filed a third-party
complaint against Ricardo Santiago and Jimmy Basilio, owner/operator
and driver of the KC-20, respectively.

ISSUE:
Whether or not the appellate court erred in holding them liable for
damages based on the findings of facts adduced by the trial court.

RULING:
 It is clear that the proximate cause of the injuries suffered by
respondent Lugue was the collision between the KC-20 and the tanker
truck. As correctly pointed out by the lower court, proximate legal cause
is that acting first and producing the injury either immediately or by
setting other events in motion, all constituting a natural and continuous
chain of events, each having a close causal connection with its immediate
predecessor, the final event in the chain immediately effecting the injury
as a natural and probable result of the cause which first acted, under
such circumstances that the person responsible for the first event should,
as an ordinarily prudent and intelligent person, have reasonable ground
to expect at the moment of his act or default that an injury to some
person might probably result therefrom. Certainly, even assuming that
petitioner Gonzales had a few seconds before actual collision, he no
longer had any opportunity to avoid it. Petitioner Gonzales cannot be
deemed negligent for failing to prevent the collision even after applying
all means available to him within the few instants when he had
discovered the impending peril.