Alberta Yobido v. Court of Appeals

Summary

This case involves a breach of contract of carriage where passenger Tito Tumboy died when a Yobido Liner bus fell into a ravine after its left front tire exploded. The bus operators claimed the tire explosion was a caso fortuito exempting them from liability, but both the Court of Appeals and Supreme Court rejected this defense. The courts held that common carriers are presumed negligent when passengers die, and this presumption was not overcome despite the tire being new and of good quality. The Supreme Court emphasized that human factors were involved and that carriers must prove extraordinary diligence, not merely that equipment was new. The case establishes that mechanical failures, even of new equipment, do not automatically constitute fortuitous events exempting carriers from liability, particularly when proper precautionary measures for road conditions are not proven.