Baliwag Transit v. Court of Appeals

Summary

This Supreme Court decision establishes important precedents on common carrier liability under Philippine law. Baliwag Transit, a bus company, was held solely liable for passenger injuries resulting from a collision with a stalled truck. The Court emphasized that common carriers owe extraordinary diligence to passengers and are presumptively liable for passenger injuries unless they prove compliance with this standard. The driver's gross negligence - excessive speed, alcohol impairment, inattentiveness, and ignoring safety warnings - constituted clear breach of the carrier's duty. The Court rejected the carrier's attempt to shift blame to the truck owner, finding that a kerosene lamp adequately satisfied early warning device requirements. The decision clarifies that moral damages are recoverable in carrier breach cases involving bad faith or gross negligence, and reinforces strict liability standards for public transportation, prioritizing passenger safety over carrier defenses.