People'S General Insurance Corporation v. Saulog Transit

Summary

PGIC, as subrogee of insured Romeo Nuqui, sought reimbursement from Saulog Transit and its driver Edward Capulong for damages from a vehicular accident on NLEX. All courts consistently found that the proximate cause was the negligence of Toyota driver Narciso Cayabyab, who stopped suddenly on the fast lane during poor visibility without activating hazard lights, rather than the bus driver's actions. The Supreme Court denied PGIC's petition, ruling it raised only questions of fact inappropriate for certiorari review. The case establishes that an insurer stands in the shoes of its insured and cannot recover when the insured's own negligence proximately caused the loss. The decision reinforces the doctrine that factual findings of lower courts, when consistent and supported by evidence, are binding on the Supreme Court absent exceptional circumstances.