Mauricio Manliclic v. Modesto Calaunan

Summary

This Supreme Court decision involves a vehicular accident case where Philippine Rabbit bus driver Mauricio Manliclic and his employer PRBLI were held solidarily liable for damages to jeep owner Modesto Calaunan. The collision occurred on July 12, 1988, at the North Luzon Expressway when the bus hit the jeep from behind. The Court resolved key issues including admissibility of transcripts from related criminal proceedings despite hearsay objections, the effect of criminal acquittal on civil liability for quasi-delict, and employer's vicarious liability. The Court emphasized that acquittal in criminal cases does not bar civil liability based on quasi-delict under Article 2176 of the Civil Code, and that employers must prove due diligence in both selection and supervision of employees. The decision modified damage awards, reducing moral and exemplary damages from P100,000.00 each to P50,000.00 each while maintaining actual damages and attorney's fees.