- Petitioner
- Viron Transportation Co.
- Respondent
- Alberto Delos Santos y Natividad
- Citation
- G.R. No. 138296
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Gonzaga-Reyes, J.
- Decided
- November 22, 2000
Summary
This case involves a vehicular accident on August 16, 1993, between a Viron Transportation bus and a cargo truck in Tarlac. The Supreme Court affirmed the lower courts' finding that the bus driver was negligent in attempting to overtake the truck despite oncoming traffic and road conditions. Under Article 2180 of the Civil Code, Viron Transportation was held liable as employer due to the presumption of negligence in employee supervision, which it failed to rebut. The Court modified the damages award, deleting actual damages for lack of proper proof and substituting P10,000.00 temperate damages under Article 2224. The attorney's fees award was also deleted for not meeting the requirements under Article 2208. The case demonstrates the application of quasi-delict principles and employer liability in vehicular accidents.