Philippine National Construction Corporation v. Hon. Court of Appeals

Summary

This case involves a vehicular accident on the North Luzon Expressway where Rodrigo Arnaiz's car overturned after running over scattered sugarcanes, injuring passenger Regina Latagan. The Supreme Court held both PNCC (tollway operator) and PASUDECO (sugar company) jointly and severally liable for damages. PASUDECO's trucks spilled sugarcane on the expressway, and while their personnel cleared the bulk of the spillage, flattened sugarcanes remained scattered on the wet road. PNCC negligently removed warning devices prematurely, failing to maintain the expressway safe for motorists. The Court applied the doctrine of joint tortfeasorship under Article 2194 of the Civil Code, finding that both defendants' successive negligent acts were the proximate cause of the accident. Although the driver exhibited contributory negligence, it was merely contributory and did not absolve the defendants of liability. The case establishes important precedent on the joint liability of tollway operators and users for accidents caused by successive acts of negligence.