Ucpb General Insurance v. Pascual Liner

Summary

UCPB General Insurance sought to recover P350,000 from Pascual Liner through subrogation after paying its insured's claim for a vehicular accident. The Supreme Court resolved conflicting rulings on the admissibility of traffic accident reports as hearsay evidence. While the Court of Appeals excluded the reports for failing hearsay exceptions, the Supreme Court held that Pascual Liner waived its objection by not timely challenging admissibility during trial. The Court applied res ipsa loquitur doctrine, establishing that hearsay evidence proving negligence carries probative weight when unopbjected, as the doctrine creates presumption of negligence independent of the evidence's hearsay character. The accident's circumstances - bus rear-ending the insured vehicle - established negligence without need for cross-examination. The decision clarifies the intersection between evidence rules and tort liability presumptions in insurance subrogation cases.