R Transport Corp. v. Pante
REITERATIONFacts
The Antecedents: Respondent Eduardo Pante was a passenger on petitioner R Transport Corporation's bus when, due to the driver's alleged fast and reckless driving, the bus collided with a tree and a house. Respondent sustained physical injuries, including a fractured right humerus, requiring hospitalization, surgery, and medication. He was unable to work for nearly a year due to his injuries. Despite initial partial assistance from the petitioner, respondent's subsequent demands for reimbursement of medical and hospitalization expenses were refused. Procedural History: Respondent filed a complaint for damages against petitioner with the Regional Trial Court (RTC) of Gapan City. Petitioner raised the defense of exercising diligence of a good father of a family and force majeure. After several postponements and declarations of default and waiver of rights due to petitioner's repeated absences and motions, the RTC ruled in favor of the respondent, awarding actual, moral, and exemplary damages. The Court of Appeals affirmed the RTC's decision, and subsequently denied petitioner's motion for reconsideration. Petitioner then filed the present petition for review on certiorari. The Petition: Petitioner seeks review of the Court of Appeals' decision and resolution, arguing that the appellate court erred in not giving due course to its motion for reconsideration, thereby violating its right to due process. Petitioner also contends that the Court of Appeals erred in affirming the RTC's decision, asserting that no substantial evidence was presented to support the award of damages, and that the trial court committed errors in its findings of fact and application of law. Specifically, petitioner challenges the admissibility of the statement of account for actual damages, the propriety of moral damages in a breach of contract of transportation, and the award of exemplary damages, claiming it did not act in a wanton or reckless manner.
Issue(s)
Whether petitioner was denied due process. Whether the Court of Appeals erred in affirming the RTC's award of damages without substantial evidence. Whether the Court of Appeals erred in its findings of facts and application of law. Whether the award of actual damages based on a statement of account is proper. Whether moral damages are recoverable in an action for breach of contract of transportation. Whether exemplary damages are proper given the circumstances.
Ruling
The petition is denied. The decision of the Court of Appeals is affirmed in toto. Petitioner R Transport Corporation is ordered to pay respondent Eduardo Pante ₱39,112.60 as actual damages; ₱50,000.00 as moral damages; and ₱50,000.00 as exemplary damages. Twenty-five percent (25%) of the total amount shall constitute a lien as contingent fee for respondent's counsel.
Ratio Decidendi
On the issue of due process: The Court held that petitioner was not denied due process. The records showed that petitioner was given ample opportunities to present its evidence, but it repeatedly failed to appear during scheduled hearings, leading to the waiver of its right to present evidence. The Court reiterated the principle that there is no denial of due process where a party was given an opportunity to be heard, and that a party cannot blame the court for its own failure to attend hearings. On the award of damages without substantial evidence: The Court found no merit in the contention that damages were awarded without substantial evidence. The testimonial evidence of the respondent established the negligence of the bus driver, leading to the vehicular accident and the respondent's injuries. The presumption of negligence against common carriers under Article 1756 of the Civil Code was not overcome by the petitioner. On the Court of Appeals' findings of facts and application of law: This issue is addressed implicitly in the rulings on the specific issues of damages and due process, as the Court's findings on those issues reflect its assessment of the facts and applicable law. On the award of actual damages based on a statement of account: The Court affirmed the admissibility of a statement of account as evidence for hospitalization expenses, citing the precedent in Jarco Marketing Corporation v. Court of Appeals. Therefore, the award of ₱22,870.00 based on the statement of account from Baliuag District Hospital was proper. On the recoverability of moral damages: The Court sustained the award of moral damages, citing Spouses Ong v. Court of Appeals. It held that a person is entitled to the integrity of his body, and if violated, damages are due. The physical pain, mental anguish, and anxiety suffered by the respondent due to the fracture of his humerus and the need for a second operation justified the award of ₱50,000.00 in moral damages. On the award of exemplary damages: The Court found the award of exemplary damages proper under Article 2232 of the Civil Code. The testimonial evidence indicated that the bus driver was driving at excessive speed in a reckless, negligent, and imprudent manner, causing the accident. Exemplary damages are intended to serve as an example or correction for the public good, which is warranted in this case.
Main Doctrine
Common carriers are presumed to have acted negligently in case of death or injuries to passengers, and must prove they observed extraordinary diligence. This liability extends to injuries caused by employees' negligence, regardless of the scope of authority, and is not absolved by proving diligence in selection and supervision. A statement of account is admissible evidence for hospitalization expenses, and moral and exemplary damages are recoverable for physical injuries sustained due to the common carrier's negligence.