National Trucking v. Right Forwarders
REITERATIONFacts
The Antecedents: Petitioner National Trucking and Forwarding Corporation (NTFC) owned a trailer tractor carrying textile carpets. On January 27, 1989, while traversing the national highway in Lubao, Pampanga, the tractor was hit by a Nissan Pulsar car owned and driven by respondent Solomon Shauf. The collision caused the Nissan car to explode and the trailer tractor to catch fire, destroying the carpets. During the investigation, it was determined that a 10-wheeler truck owned by respondent Right Forwarders Corporation (RFC) hit the rear of Shauf's Nissan car, causing it to swerve and collide with NTFC's trailer. Procedural History: NTFC filed a complaint for damages against Shauf and RFC, including its President and Manager, spouses Roberto and Shirley Cruz Pagotan. Shauf filed a cross-claim against RFC, and RFC filed a counterclaim against Shauf. The Regional Trial Court (RTC) of Manila, Branch 16, found RFC liable for the collision, ruling that its truck driver attempted to overtake Shauf but slowed down upon seeing NTFC's trailer, and in regaining position, hit Shauf's car, causing Shauf to lose control and collide with NTFC's trailer. The RTC awarded damages to NTFC and Shauf. RFC appealed to the Court of Appeals (CA). Initially, the CA affirmed the RTC decision. However, upon RFC's motion for reconsideration, the CA vacated its prior ruling, reversed its decision, and dismissed NTFC's complaint and Shauf's cross-claim, finding that the trial court overlooked a police report indicating Shauf overtook RFC's truck and sideswiped it. The Petition: NTFC filed a petition for review with the Supreme Court, faulting the CA for reversing its earlier decision and leaving NTFC without recourse for its damages.
Issue(s)
Whether the Court of Appeals erred in reversing its earlier decision and dismissing the complaint and cross-claim, particularly regarding the contradictory factual findings concerning responsibility for the collision and damages. Whether the findings of fact of the trial court regarding the credibility of evidence and the role of the police report should be given deference, especially in light of contradictory findings by the Court of Appeals.
Ruling
The petition is GRANTED. The assailed resolution of the Court of Appeals is SET ASIDE. The decision of the Regional Trial Court of Manila, Branch 16, is REINSTATED.
Ratio Decidendi
On the issue of appellate review and factual findings: The Supreme Court held that this case falls under one of the exceptions to the rule that it does not review factual findings of lower courts, specifically because there were contradictory factual findings as to who was responsible for the collision and who should pay damages. The Court found it necessary to pass on the facts and evidence of the case to resolve the conflicting conclusions of the RTC and the CA. The Court emphasized that it can review factual findings when such findings are not supported by evidence or when the CA's findings are contrary to those of the RTC, as in this instance. On the credibility of evidence and the role of the police report: The Supreme Court deferred to the trial court's evaluation of the evidence and the credibility of witnesses. It found the testimony of RFC's driver, claiming the car tried to overtake the truck, to be self-serving and unbelievable, contrary to ordinary human experience. The Court noted that the physical condition of the RFC truck, which emerged from the accident with minimal damage, contradicted the claim that it was hit by a car attempting to overtake. Furthermore, the Court gave little probative value to the police report relied upon by the CA, as the author of the report never testified to attest to its truthfulness. While acknowledging that such reports are prima facie evidence, the Court stated they can be negated by clear and convincing evidence to the contrary, which it found present in this case.
Main Doctrine
The Supreme Court may pass on factual findings of lower courts when there are contradictory findings as to who is responsible for a collision and who should pay damages. A police report, while prima facie evidence, may be negated by clear and convincing evidence to the contrary, especially if the author thereof did not testify.