Lapanday Agricultural and Development Corporation v. Angala
REITERATIONFacts
The Antecedents: On May 4, 1993, a Datsun crewcab owned by Lapanday Agricultural and Development Corporation (LADECO), driven by Apolonio Deocampo, collided with a 1958 Chevy pick-up owned by Michael Raymond Angala, driven by Bernulfo Borres. The incident occurred on Rafael Castillo St., Agdao, Davao City. The pick-up sustained damage to its left door, front left fender, and bumper. Angala alleged that his pick-up was slowing down to make a left turn when it was bumped from behind by the crewcab, which was allegedly speeding. Angala claimed to have heard a screeching sound before the impact. Procedural History: Angala filed a case for Quasi-Delict, Damages, and Attorney's Fees against LADECO, Henry Berenguel, and Deocampo. The Regional Trial Court (RTC) found LADECO and Deocampo solidarily liable for actual damages, moral damages, and attorney's fees, ruling that Deocampo's speed was the proximate cause and that he had the last opportunity to avoid the accident. The RTC found Berenguel not liable. The Court of Appeals (CA) affirmed the RTC's decision in toto, applying the doctrine of last clear chance and holding LADECO solidarily liable under Article 2180 of the Civil Code. The Petition: LADECO and Deocampo filed a petition for review with the Supreme Court, assailing the CA's decision and resolution. The issues raised were whether Section 45(b) of RA 4136 and Article 2185 of the Civil Code applied, and whether Angala was entitled to the awarded damages.
Issue(s)
Whether Section 45(b) of Republic Act No. 4136 and Article 2185 of the Civil Code apply to this case, and the applicability of the Doctrine of Last Clear Chance, and the solidary liability of LADECO. Whether respondent is entitled to the damages awarded.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals with modification, deleting the award of attorney's fees. The Court held that both drivers were negligent, but the doctrine of last clear chance applied, making Deocampo liable. LADECO was held solidarily liable with Deocampo. The award for moral damages was sustained, but attorney's fees were deleted due to lack of justification.
Ratio Decidendi
On the applicability of Section 45(b) of RA 4136 and Article 2185 of the Civil Code, the Doctrine of Last Clear Chance, and the solidary liability of LADECO: The Court ruled that both parties were negligent. Borres, driving the pick-up, was negligent in executing a U-turn from the outer lane, violating Section 45(b) of RA 4136, which requires a left turn to be approached from the lane nearest to the center line. However, Deocampo, driving the crewcab, was equally negligent. He was driving at a very fast speed, failing to slow down when the pick-up ahead slowed down in preparation for the U-turn. Deocampo admitted noticing the pick-up about 20 meters away but did not apply the brakes until after the collision. The Court sustained the findings of the lower courts that Deocampo's speed was excessive, as evidenced by the crewcab stopping 21 meters from the point of impact. Given that both parties were found negligent, the Court applied the doctrine of last clear chance. This doctrine holds that the party who had the last clear opportunity to avoid the loss but failed to do so is chargeable with the loss. The Court found that Deocampo, driving the rear vehicle, had full control of the situation and the last clear chance to avoid the collision. He should have slowed down when the pick-up ahead slowed down and should have applied his brakes upon seeing the pick-up, instead of only doing so after the impact. His excessive speed prevented him from exercising this last clear opportunity. The Court affirmed the solidary liability of LADECO with Deocampo. LADECO claimed it exercised due diligence in the selection and supervision of its employees but failed to present any proof to substantiate this claim. Without evidence of its policies on hiring or supervision, LADECO could not escape liability under Article 2180 of the Civil Code, which presumes the negligence of the employee to be the negligence of the employer unless the latter proves they exercised due diligence. On the entitlement to damages: The Court sustained the award of actual damages and moral damages. The trial court found that Angala suffered shock, serious anxiety, and fright due to the collision, which justified the award of moral damages. However, the award of attorney's fees was deleted. The Court noted that both the trial court and the Court of Appeals failed to provide any justification for the award of attorney's fees, emphasizing that such awards must be based on findings of fact and law stated in the decision.
Main Doctrine
Both drivers were found negligent, but the doctrine of last clear chance applied, holding the driver of the rear vehicle (Deocampo) liable for failing to avoid the collision despite having the last clear opportunity to do so. The employer (LADECO) was held solidarily liable due to failure to prove due diligence in the selection and supervision of employees. The award for attorney's fees was deleted due to lack of justification.