B.F. Metal (Corporation) v · G.R. 170813

Petitioner: B.F. Metal (Corporation)
Respondent: Sps. Rolando M. Lomotan
Citation: G.R. No. 170813
Court: Supreme Court
Division: Second Division
Ponente: Tinga, J.
Decided: April 16, 2008

Summary

This case involved a vehicular accident where B.F. Metal Corporation's truck driver Onofre Rivera overtook a vehicle and collided with a jeep owned by Spouses Lomotan and driven by Rico Umuyon, causing total wreck of the jeep and serious physical injuries to Umuyon. The Supreme Court found both Rivera and B.F. Metal Corporation liable for quasi-delict under Article 2180 of the Civil Code due to the driver's negligence and the employer's failure to exercise due diligence in employee selection and supervision. The Court reduced actual damages to the jeep's acquisition cost of P72,000, reasoning that repair estimates are insufficient proof of actual damages. Moral damages were limited to the injured driver Umuyon only, while exemplary damages and attorney's fees were affirmed for deterrent purposes. The decision clarifies standards for proving actual damages and limits moral damages to those who actually suffered physical injuries in quasi-delict cases.

Statutes applied

Civil Code, Art. 2180

Related cases

Other Philippine cases on the same provisions and issues.

Bataclan v. Medina G.R. No. L-10126
Africa v. Caltex (Phil.), Inc. G.R. No. L-12986
Spouses Benjamin C. Mamaril v. The Boy Scout of the Philippines G.R. No. 179382
Spouses Fernando v. Continental Airlines G.R. No. 188288
Cornelio Lampesa v. Dr. Juan de Vera, Jr. G.R. No. 155111
Keihin-Everett Forwarding Co. v. Tokio Marine Malayan Insurance Co. G.R. No. 212107
National Transmission Corporation v. Leslie L. de Jesus G.R. No. 217928
Rcj Bus Lines v. Standard Insurance Company G.R. No. 193629

By the Intellegal Editorial Board · April 16, 2008

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