- Petitioner
- Judith D. Darines
- Respondent
- Eduardo Quiñones
- Citation
- G.R. No. 206468
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Del Castillo, J.
- Decided
- August 2, 2017
Summary
This case involves a bus accident where passengers sued the bus operator and driver for breach of contract of carriage. Petitioners Judith and Joyce Darines were injured when their Amianan Bus crashed into a parked truck on December 31, 2005. The RTC initially awarded moral and exemplary damages plus attorney's fees, but the CA reversed, finding no fraud or bad faith by respondents. The Supreme Court affirmed the CA, establishing that in contract of carriage cases, moral damages require either passenger death or carrier fraud/bad faith. Since respondents paid medical expenses and showed no deliberate wrongdoing, only negligence was proven, which is insufficient for moral damages under Article 2220 of the Civil Code. The decision clarifies the distinction between contractual breach and quasi-delicts in transportation law.