Facts:
Case: Gashem Shookat Baksh v. Court of Appeals
Petitioner: Gashem Shookat Baksh, an Iranian citizen studying in the Philippines
Private Respondent: Marilou T. Gonzales
Petitioner courted the private respondent and proposed marriage to her
Private respondent accepted on the condition of marriage
They agreed to get married after the school semester
Petitioner visited private respondent's parents for their approval
Petitioner repudiated the marriage agreement a week before the complaint was
filed
It was discovered that the petitioner was already married to someone else in
Bacolod City
Issue:
Whether damages may be recovered for a breach of promise to marry based on
Article 21 of the Civil Code
Ruling:
Damages may be awarded for a breach of promise to marry if:
The promise was made with fraudulent and deceptive intent
The injury caused by the breach was committed in a manner contrary to morals,
good customs, or public policy
In this case, the court found that:
The petitioner's fraudulent and deceptive protestations of love and promise to
marry the private respondent led her to surrender her virtue and reputation to him
The petitioner's actions were against morals, good customs, and public policy
Therefore, the petitioner should be held liable for damages
Ratio:
Article 21 of the Civil Code provides a legal remedy for moral wrongs that are
impossible to specifically enumerate and punish in the statute books
Damages may be awarded in cases of breach of promise to marry accompanied by
fraud and deceit, resulting in injury to the honor and reputation of the aggrieved
party
The court emphasized the importance of protecting women's honor and dignity and
preventing foreigners from taking advantage of Filipino customs and traditions
The pari delicto rule does not apply in cases of moral seduction, where the
aggrieved party is not in equal fault with the wrongdoer.
Title
Guevarra, et al. vs. Banach
In the case of Guevarra v. Banach, the Supreme Court ruled in favor of Jhonna
Guevarra, stating that a breach of promise to marry is not an actionable wrong as
long as it does not contradict good customs, and the party seeking damages must
have acted in good faith.
Facts:
Jan Banach, a German citizen, met Jhonna Guevarra through Pastor Jun Millamina.
Banach courted Guevarra, visiting her almost every day, giving her gifts, and
expressing his intention to marry her.
Banach did not disclose that he was still married to his third wife and presented
himself as a divorced man named Roger Brawner.
Guevarra agreed to marry Banach and he sent her P500,000.00 to buy a lot for their
conjugal home.
Guevarra discovered Banach's lies and deception and broke up with him.
Banach sued Guevarra and her parents for damages, alleging fraud and unjust
enrichment.
Issue:
Is the order to return the P500,000.00 given by Banach to Guevarra proper?
Ruling:
The Supreme Court ruled in favor of Guevarra and deleted the award of damages to
Banach.
Ratio:
A mere breach of promise to marry is not an actionable wrong, as long as it does not
contradict good customs.
The party seeking damages must have acted in good faith.
Guevarra called off the engagement after discovering Banach's lies and deception.
Banach's actions were tainted with fraud and deceit, and he did not have the purest
intentions in marrying Guevarra.
Guevarra cannot be compelled to return the P500,000.00 given to her as it was a
gift.
The Court reiterated the doctrine that a breach of promise to marry is not an
actionable wrong, unless it palpably and unjustifiably contradicts good customs.
The party seeking damages must have acted in good faith.
Banach's actions were fraudulent and deceitful, justifying Guevarra's decision to call
off the engagement.
The Court recognized the fundamental right to marry and the importance of
individual autonomy in choosing a life partner.
Courts should not meddle in personal affairs and discourage litigation in matters of
broken promises in intimate relationships.
Barredo vs. Garcia
The court rules in favor of the plaintiffs, establishing the primary liability of an
employer for the negligence of their employee, separate from criminal liability, in a
case involving a fatal collision between a carretela and a taxi.
Facts:
The case involves the death of a 16-year-old boy, Faustino Garcia, who was a
passenger in a carretela (horse-drawn carriage) that was involved in a head-on
collision with a taxi driven by Pedro Fontanilla, an employee of Fausto Barredo, the
proprietor of the taxi.
Fontanilla was convicted and sentenced in a criminal case, and the court granted the
petition to reserve the right to bring a separate civil action.
The parents of the deceased brought a civil action for damages against Barredo,
arguing that he was primarily and directly responsible for the negligence of his
employee under articles 1902 and 1903 of the Civil Code.
Issue:
Can the plaintiffs bring a separate civil action against Barredo, making him primarily
and directly responsible for the damages caused by his employee's negligence?
Ruling:
The court rules in favor of the plaintiffs, stating that a separate civil action lies and
that the employer is primarily and directly responsible for the negligent acts of his
employee under articles 1902 and 1903 of the Civil Code.
Ratio:
A quasi-delict or "culpa aquiliana" is a separate legal institution under the Civil Code,
with its own substantivity and individuality.
The primary and direct responsibility of employers can be anchored on the wording
and spirit of article 1903 of the Civil Code.
Cuasi-delitos have a distinctive nature that survives in the Civil Code, and they are
governed by articles 1902-1910.
Civil liability arising from a crime and responsibility for cuasi-delitos or culpa extra-
contractual are distinct.
The plaintiffs are free to choose which remedy to enforce.
The liability of the employer is not subsidiary under the Revised Penal Code.
The legal institution of cuasi-delito would have little application if the employer's
liability is considered subsidiary only to criminal liability.
There are cases of criminal negligence that cannot be proven beyond reasonable
doubt but can be proved by a preponderance of evidence.
The primary and direct responsibility of the employer under article 1903 of the Civil
Code is more likely to facilitate a remedy for civil wrongs and protect society.
Relying solely on civil responsibility for a crime harms the principle of responsibility
for fault or negligence under articles 1902 et seq. of the Civil Code.
The separate individuality of cuasi-delitos under the Civil Code has been recognized
in previous decisions of the Supreme Court of the Philippines.
Conclusion:
The court's ruling establishes the primary liability of an employer for the negligence
of their employee under articles 1902 and 1903 of the Civil Code.
The court emphasizes the distinct nature of cuasi-delitos and the employer's direct
responsibility, separate from criminal liability.
The court's decision is based on the interpretation of the Civil Code, the historical
development of cuasi-delitos, and the need for an expeditious remedy for civil
wrongs.

Lumantas vs. Calapiz
A doctor is acquitted of a criminal charge but held liable for civil damages after
performing a circumcision that resulted in serious physical injuries to a patient,
highlighting the distinction between criminal and civil liability.
Facts:
The case involves Dr. Encarnacion C. Lumantas, M.D. as the petitioner and Hanz
Calapiz, represented by his parents Hilario Calapiz, Jr. and Herlita Calapiz, as the
respondent.
The incident occurred on January 16, 1995, when the parents brought their 8-year-
old son, Hanz, to the Misamis Occidental Provincial Hospital for an emergency
appendectomy.
The petitioner suggested that Hanz also undergo circumcision at no added cost, and
with the parents' consent, performed the circumcision after the appendectomy.
The following day, Hanz complained of pain and exhibited blisters on his penis, and
his testicles were swollen.
Hanz was discharged from the hospital on January 30, 1995, but was later confined
again due to abscess formation between the base and shaft of his penis.
Hanz's parents filed a criminal charge against the petitioner for reckless imprudence
resulting in serious physical injuries.
The Municipal Trial Court in Cities of Oroquieta City transferred the case to the
Regional Trial Court (RTC) pursuant to Supreme Court Circular No. 11-99.
The RTC acquitted the petitioner of the crime charged due to insufficiency of
evidence, but ordered him to pay moral damages to Hanz.
The Court of Appeals (CA) affirmed the RTC's decision, stating that the petitioner's
acquittal did not absolve him from civil liability.
The petitioner appealed to the Supreme Court.
Issue:
Whether the CA erred in affirming the petitioner's civil liability despite his acquittal
of the crime of reckless imprudence resulting in serious physical injuries.
Ruling:
The petition for review lacks merit.
The acquittal of an accused does not necessarily extinguish his civil liability.
There are two kinds of acquittal recognized by law: one where the accused is not the
author of the act or omission complained of, and one based on reasonable doubt on
the guilt of the accused.
In this case, the petitioner was acquitted due to insufficiency of evidence, but his
civil liability can still be adjudged based on preponderance of evidence.
The failure to prove criminal negligence does not prevent a finding of civil liability.
The RTC and the CA both found that Hanz sustained the injurious trauma from the
petitioner's circumcision, and that the trauma could have been avoided.
The Court must accord the highest respect to the factual findings of the trial court
and the CA, unless there is a clear showing of arbitrariness, capriciousness, or
palpable error.
Every person is entitled to the physical integrity of their body, and civil damages
should be assessed once that integrity has been violated.
In Hanz's case, his physical and moral sufferings warranted the award of P50,000.00
as moral damages.
Interest of 6% per annum should be imposed on the award from the filing of the
criminal information on April 17, 1997.
Ratio:
The acquittal of an accused does not necessarily absolve him from civil liability.
There are two kinds of acquittal recognized by law: one where the accused is not the
author of the act or omission complained of, and one based on reasonable doubt on
the guilt of the accused.
In this case, the petitioner was acquitted due to insufficiency of evidence, but his
civil liability can still be adjudged based on preponderance of evidence.
The failure to prove criminal negligence does not prevent a finding of civil liability.
The Court must accord the highest respect to the factual findings of the trial court
and the CA, unless there is a clear showing of arbitrariness, capriciousness, or
palpable error.
Every person is entitled to the physical integrity of their body, and civil damages
should be assessed once that integrity has been violated.
In Hanz's case, his physical and moral sufferings warranted the award of P50,000.00
as moral damages.
Interest of 6% per annum should be imposed on the award from the filing of the
criminal information on April 17, 1997.
Manliclic vs. Calau
A collision between a Philippine Rabbit Bus and an owner-type jeep leads to a legal
battle as the Supreme Court upholds the decision that the bus driver and the bus
company are liable for damages, despite their claims of negligence and due
diligence.
Facts:
The collision occurred on July 12, 1988, along the North Luzon Expressway in
Barangay Lalangan, Plaridel, Bulacan.
The jeep, owned by respondent Modesto Calaunan and driven by Marcelo Mendoza,
was traveling from Pangasinan to Manila.
The bus, owned by petitioner Philippine Rabbit Bus Lines, Inc. (PRBLI) and driven by
petitioner Mauricio Manliclic, was heading from Concepcion, Tarlac to Manila.
The front right side of the bus collided with the rear left side of the jeep, causing
extensive damage to both vehicles.
Respondent Calaunan suffered minor injuries and was brought to the Manila Central
University Hospital for treatment.
He filed a complaint for damages against petitioners Manliclic and PRBLI.
A criminal case was also filed against Manliclic for reckless imprudence resulting in
damage to property with physical injuries.
The trial court found Manliclic negligent and held both Manliclic and PRBLI solidarily
liable for damages.
The court awarded respondent actual damages for the towing and repair of his jeep,
as well as moral damages, exemplary damages, and attorney's fees.
Petitioners appealed the decision to the Court of Appeals, which affirmed the trial
court's decision.
Petitioners filed a petition for review with the Supreme Court, raising several errors
in the Court of Appeals' decision.
Issue:
Who is liable for the collision between the bus and the jeep?
Ruling:
Petitioners Manliclic and PRBLI are held solidarily liable for damages.
Ratio:
The Supreme Court first addressed the admissibility of the transcripts of
stenographic notes (TSNs) from the criminal case in the civil case. The Court ruled
that petitioners had waived their objection by failing to raise it during the trial.
Therefore, the TSNs were admitted as evidence.
The Court considered the conflicting versions of the parties regarding how the
collision occurred. After reviewing the evidence, the Court agreed with the trial
court's finding that petitioner Manliclic was negligent in driving the bus, causing the
collision. The Court emphasized that it would not disturb the factual findings of the
trial court unless there were exceptional circumstances, which were not present in
this case.
Regarding petitioner PRBLI's defense of due diligence in the selection and
supervision of its employees, the Court found that PRBLI failed to prove that it had
exercised the required diligence. The presence of investigators after the accident
was not sufficient to demonstrate proper supervision. The Court held PRBLI
solidarily liable with Manliclic for the damages.
Finally, the Court modified the awards of damages. The actual damages awarded for
the towing and repair of the jeep were upheld. However, the moral damages and
exemplary damages were reduced to P50,000 each. The attorney's fees and
expenses of litigation were deemed appropriate and upheld.
Garcia vs. Florido
A civil action for damages filed by petitioners who sustained injuries in a car collision
is deemed not premature and should proceed to trial, as the essential elements for a
quasi-delictual action were present and the filing of the civil action effectively
abandoned their right to press recovery for damages in the criminal case.
Facts:
German C. Garcia, Luminosa L. Garcia, and Ester Francisco filed a civil action for
damages against Marcelino Inesin, Ricardo Vayson, Mactan Transit Co., Inc., and
Pedro Tumala.
The petitioners hired a PU car owned and operated by Inesin and driven by Vayson
for a roundtrip from Oroquieta City to Zamboanga City.
While on the national highway, the PU car collided with an oncoming passenger bus
owned and operated by Mactan Transit Co., Inc. and driven by Tumala.
The collision resulted in injuries to the petitioners.
Issue:
Is the civil action for damages filed by the petitioners premature due to the
pendency of a criminal case against Tumala?
Ruling:
The civil action for damages filed by the petitioners is not premature and should
proceed to trial.
The dismissal of the complaint by the lower court was reversed.
Ratio:
The essential elements for a quasi-delictual action under Articles 2176-2194 of the
New Civil Code are present in the case.
The negligent act of the drivers, the resulting injuries to the petitioners, and the
absence of pre-existing contractual relations between the parties establish the basis
for a civil action for damages.
The fact that the complaint alleged a violation of traffic rules does not change the
nature of the action, as it is still based on culpa aquiliana.
The same negligent act can give rise to both a civil liability arising from a crime and
an action for quasi-delict.
The filing of the civil action by the petitioners effectively abandoned their right to
press recovery for damages in the criminal case, and they have chosen to pursue
their claim in the civil case.
The reservation requirement under Rule 111 of the Rules of Court is not applicable
in this case, as the civil action is based on quasi-delict and not on the civil liability
imposed by the Revised Penal Code.
Therefore, the dismissal of the complaint by the lower court was unjustified, and the
case should proceed to trial.
Supreme Transportation Liner, Inc. vs. San Andres
The Supreme Court ruled in favor of the petitioners in a civil action for damages,
allowing their counterclaim and clarifying that the reservation of the civil action
does not apply to independent civil actions under certain articles of the Civil Code.
Facts:
Respondent Antonio San Andres filed a civil action for damages against petitioners
Supreme Transportation Liner, Inc. and Felix Q. Ruz.
The incident occurred on November 5, 2002, when a bus owned by San Andres
sideswiped a Toyota Revo and then collided head-on with a bus owned by Supreme
Transportation Liner.
All vehicles involved were damaged.
San Andres filed a complaint for damages, alleging actual damage to his bus and
unrealized profits.
The petitioners argued that the proximate cause of the accident was the reckless
imprudence of San Andres' driver and sought damages for the damage to their bus
and medical expenses.
The Regional Trial Court (RTC) dismissed both San Andres' complaint and the
petitioners' counterclaim, ruling that the counterclaim was not allowed due to the
failure to reserve the right to file a separate civil action in the criminal case against
San Andres' driver.
Issue:
Whether the petitioners' counterclaim was correctly denied by the RTC.
Ruling:
The Supreme Court ruled in favor of the petitioners and allowed their counterclaim.
The Court held that the requirement for the reservation of the civil action does not
apply to independent civil actions under Articles 32, 33, 34, and 2176 of the Civil
Code.
The Court clarified that the petitioners' cause of action was based on a quasi-delict,
and their counterclaim was an independent civil action.
The Court noted that the RTC erred in applying the obsolete version of the Rules of
Court, which required the reservation of the right to file a separate civil action.
The Court emphasized that the revised rule no longer includes the independent civil
actions as requiring prior reservation.
However, the Court also stated that the petitioners must demonstrate that they will
not recover damages twice for the same incident, as double recovery is prohibited
under Article 2177 of the Civil Code.
The case was remanded to the RTC for further proceedings to allow the petitioners
to present evidence on their counterclaim, subject to the prohibition against double
recovery of damages.
Casupa vs. Laroya
In the case of Casupanan v. Laroya, the court ruled that an accused in a pending
criminal case can file a separate civil action for quasi-delict against the private
complainant, and the dismissal of the civil case by the lower court was erroneous.
Facts:
Mario Llavore Laroya and Roberto Capitulo were involved in a vehicular accident.
Laroya filed a criminal case against Avelino Casupanan, the driver of Capitulo's
vehicle, for reckless imprudence resulting in damage to property.
Casupanan and Capitulo, on the other hand, filed a civil case against Laroya for
quasi-delict.
The civil case was dismissed by the Municipal Circuit Trial Court (MCTC) on the
ground of forum-shopping.
Issue:
Can an accused in a pending criminal case for reckless imprudence file a separate
civil action for quasi-delict against the private complainant in the criminal case?
Ruling:
The dismissal of the civil case by the MCTC was without prejudice, as there was no
declaration that the dismissal was with prejudice.
Therefore, the dismissal was not appealable, and the proper remedy was a special
civil action under Rule 65.
There was no forum-shopping in this case because separate civil actions can be filed
independently of criminal actions.
The accused can file a civil action for quasi-delict for the same act or omission he is
accused of in the criminal case, as expressly allowed in the rules.
The court granted the petition and reinstated the civil case, ruling that the dismissal
of the civil case by the MCTC was erroneous.
Ratio:
The dismissal of the civil case by the MCTC was without prejudice, meaning it did
not bar the refiling of the case.
Since there was no declaration that the dismissal was with prejudice, it was not
appealable.
The proper remedy in this case was a special civil action under Rule 65, which allows
for the review of judgments or final orders of lower courts.
The court clarified that there was no forum-shopping in this case because separate
civil actions can be filed independently of criminal actions.
The accused has the right to file a civil action for quasi-delict for the same act or
omission he is accused of in the criminal case.
This is expressly allowed in the rules, specifically in Section 1, Rule 111 of the Rules
of Court.
Therefore, the dismissal of the civil case by the MCTC was erroneous, and the court
granted the petition to reinstate the civil case.
Dangwa Transportation Co., Inc. vs. Court of Appeals
A common carrier is held liable for the death of a passenger due to the driver's
premature acceleration, leading to an award of indemnity, moral damages, and
actual and compensatory damages to the victim's heirs.
Facts:
On March 25, 1985, a passenger bus owned by Dangwa Transportation Co., Inc. and
driven by Theodore Lardizabal was involved in a vehicular accident in Marivic, Sapid,
Mankayan, Benguet.
The accident resulted in the death of Pedrito Cudiamat.
The heirs of Pedrito Cudiamat filed a complaint for damages against the petitioners,
alleging that the driver was driving recklessly and without regard for traffic rules and
safety.
They also claimed that the driver did not immediately bring Pedrito to the hospital
but instead prioritized other passengers and cargo.
The trial court initially ruled in favor of the petitioners, finding Pedrito Cudiamat
negligent and ordering the petitioners to pay the heirs a nominal amount.
The Court of Appeals reversed the decision and ordered the petitioners to pay
indemnity for death, moral damages, and actual and compensatory damages to the
heirs.
Issue:
Whether the Court of Appeals erred in finding the petitioners negligent and liable
for the damages claimed by the heirs.
Ruling:
The Supreme Court affirmed the decision of the Court of Appeals, holding the
petitioners liable for the death of Pedrito Cudiamat and ordering them to pay
indemnity for death, moral damages, and reduced actual damages to the heirs.
Ratio:
The driver and conductor of the bus were negligent in their actions.
When a bus stops, it is making a continuous offer to bus riders, and it is the duty of
the driver and conductor to ensure the safety of passengers boarding the bus.
The premature acceleration of the bus in this case was a breach of that duty.
It is not negligence for a person to attempt to board a slowly moving vehicle, and the
driver and conductor should have been aware of this common practice.
Common carriers, such as bus companies, are bound to observe extraordinary
diligence for the safety of their passengers.
They are obligated to carry passengers safely and are liable for injuries suffered by
boarding passengers resulting from the sudden starting or jerking of their
conveyances.
Damages:
The computation of actual damages by the Court of Appeals based on the gross
income of the victim was incorrect.
Only net earnings, after deducting necessary expenses and living expenses, should
be considered.
The Court reduced the award of actual damages but increased the death indemnity.
Conclusion:
The Supreme Court affirmed the decision of the Court of Appeals, holding the
petitioners liable for the death of Pedrito Cudiamat and ordering them to pay
indemnity for death, moral damages, and reduced actual damages to the heirs.
The Court emphasized the duty of common carriers to ensure the safety of their
passengers and the need for extraordinary diligence in their operations.
Calalas vs. Court of Appeals
A common carrier is held liable for breaching the contract of carriage and ordered to
pay damages to a passenger injured in an accident, as the carrier failed to prove that
they exercised the required diligence in ensuring passenger safety.
Facts:
Eliza Jujeurche Sunga filed a complaint for damages against Vicente Calalas, alleging
that Calalas violated the contract of carriage by failing to exercise the required
diligence as a common carrier.
Sunga was a passenger in Calalas' jeepney when it was bumped by an Isuzu truck
owned by Francisco Salva.
Sunga sustained injuries as a result of the accident.
Calalas filed a third-party complaint against Salva, claiming that Salva was
responsible for the accident.
The lower court absolved Calalas of liability and held Salva responsible for the
accident.
Calalas also filed a separate case against Salva and Verena for quasi-delict, in which
Salva and Verena were held jointly liable to Calalas for the damage to his jeepney.
On appeal, the Court of Appeals reversed the ruling of the lower court, stating that
Sunga's cause of action was based on a contract of carriage, not quasi-delict, and
that Calalas failed to exercise the required diligence.
Issue:
Whether Calalas is liable for the breach of the contract of carriage.
Ruling:
The Court of Appeals reversed the ruling of the lower court and held Calalas liable
for the breach of the contract of carriage.
Calalas was ordered to pay Sunga actual and compensatory damages, moral
damages, attorney's fees, and expenses of litigation.
The award of moral damages was later deleted.
Ratio:
The court explained that the issue in this case is whether Calalas is liable on his
contract of carriage, while the issue in the previous case (Civil Case No. 3490) was
whether Salva and his driver Verena were liable for quasi-delict.
Quasi-delict is based on the negligence of the tortfeasor, while breach of contract is
based on the negligence in the performance of a contractual obligation.
In actions involving breach of contract, the action can be prosecuted by proving the
existence of the contract and the failure of the obligor (common carrier) to transport
the passenger safely.
The court clarified that the doctrine of proximate cause, which is applicable in
actions for quasi-delict, is not applicable in actions involving breach of contract.
In this case, the presumption of negligence arose upon the happening of the
accident, and it was the duty of Calalas to prove that he had observed extraordinary
diligence in the care of his passengers.
However, Calalas failed to overcome the presumption of negligence and was found
to be actually negligent in transporting passengers.
Therefore, Calalas was held liable for the breach of the contract of carriage.
Orient Freight International, Inc. vs. Keihin-Everett Forwarding Co., Inc.
A dispute arises between Orient Freight and Keihin-Everett regarding the
termination of their contract with Matsushita, with the Supreme Court ruling that
Orient Freight's negligence in failing to report a hijacking incident constituted a
breach of contract rather than a quasi-delict.
Facts:
The case involves a dispute between Orient Freight and Keihin-Everett regarding the
termination of their contract with Matsushita Communication Industrial Corporation
of the Philippines (Matsushita).
On October 16, 2001, Keihin-Everett entered into a Trucking Service Agreement with
Matsushita, which was subcontracted to Orient Freight.
When the Trucking Service Agreement expired, Keihin-Everett executed an In-House
Brokerage Service Agreement for Matsushita's export operations.
Keihin-Everett continued to retain the services of Orient Freight, which sub-
contracted its work to Schmitz Transport and Brokerage Corporation.
In April 2002, a hijacking incident involving a truck carrying Matsushita's shipment
occurred.
Orient Freight initially reported that the incident was a breakdown and towing of the
truck, but it was later discovered that 10 pallets of the shipment were missing.
Matsushita terminated its contract with Keihin-Everett, citing loss of confidence due
to Orient Freight's failure to disclose the true facts of the incident.
Issue:
Whether the failure to state the names of the parties in the petition violates
procedural rules.
Whether the Court of Appeals erred in applying Article 2176 of the Civil Code.
Whether Orient Freight was negligent in failing to disclose the facts of the hijacking
incident.
Whether the trial court erred in the computation of the awarded damages.
Ruling:
The failure to state the names of the parties in the petition does not violate
procedural rules.
The Court of Appeals did not err in applying Article 2176 of the Civil Code.
Orient Freight was negligent in failing to disclose the facts of the hijacking incident.
The trial court did not err in the computation of the awarded damages.
Ratio:
The Court ruled that the failure to state the names of the parties in the petition does
not violate procedural rules, as the names are readily discernable from the caption
of the petition.
The Court held that the Court of Appeals did not err in applying Article 2176 of the
Civil Code, as negligence may apply even in cases with a pre-existing contractual
relation.
However, the Court clarified that the duty to report the hijacking incident arose
subsequent to the Trucking Service Agreement, and therefore, the provisions on
quasi-delict were inapplicable.
The Court found that Orient Freight was negligent in failing to adequately investigate
and report the hijacking incident to Keihin-Everett, despite being directed to do so.
The Court upheld the findings of the trial court and the Court of Appeals that Orient
Freight's negligence caused Keihin-Everett to suffer income losses due to
Matsushita's termination of their contract.
The Court affirmed the computation of damages made by the trial court.
In conclusion, the Court denied the petition and affirmed the decision of the Court
of Appeals, ruling that Orient Freight's negligence constituted a breach of contract
rather than a quasi-delict.
Spouses Dalen vs. Mitsui O.S.K. Lines
A complaint for damages filed by the spouses Dalen against non-resident
corporations involved in the sinking of a vessel is dismissed by the Supreme Court
due to lack of jurisdiction and the validity of settlement agreements.
Facts:
Magsaysay Maritime Corporation hired crew members for the MV Sea Prospect,
which was chartered by Mitsui O.S.K. Lines and owned by Diamond Camellia, S.A.
On August 26, 1998, the vessel sank, resulting in the death of 10 crew members.
The heirs of the deceased crew members filed a complaint for damages against
Mitsui O.S.K. Lines and Diamond Camellia, S.A.
The respondents alleged that the heirs had already received full payment of death
benefits based on settlement agreements and the Collective Bargaining Agreement
governing their employment.
The settlement agreements released the respondents from all liabilities, including
those based on tort, arising from the sinking of the vessel.
Issue:
Whether the heirs' cause of action has prescribed.
Whether the settlement agreements barred the heirs from filing the complaint.
Ruling:
The Labor Arbiter lacks jurisdiction over tort cases.
The settlement agreements signed by the heirs were valid and binding.
Ratio:
The claim for damages based on tort filed by the heirs before the Labor Arbiter was
not within the ambit of the labor court's jurisdiction.
The claim for damages arising from the sinking of the vessel was a quasi-delict,
which falls under the jurisdiction of the regular court.
The settlement agreements were voluntarily entered into by the heirs with the
assistance of their chosen counsel.
The agreements released the respondents from all liabilities, including those based
on tort, arising from the sinking of the vessel.
There was no evidence that the agreements were unconscionable or that the heirs
were tricked into signing them.
The Supreme Court affirmed the decision of the Court of Appeals, which dismissed
the complaint for damages filed by the heirs.
The Court held that the Labor Arbiter lacks jurisdiction over tort cases and that the
settlement agreements signed by the heirs were valid and binding.
Air France vs. Carrascoso
Air France is ordered to pay Rafael Carrascoso damages and attorney's fees after
wrongfully expelling him from his first-class seat and forcing him to sit in the tourist
class, with the Court of Appeals finding that Air France breached the contract and
acted in bad faith.
Facts:
Parties involved: Air France and Rafael Carrascoso
Date and place: Not specified
Carrascoso purchased a first class round trip airplane ticket from Air France for a trip
from Manila to Rome.
During the first two legs of the trip, Carrascoso was provided with first class
accommodations.
At Bangkok, the manager of Air France forced Carrascoso to vacate his first class seat
and sit in the tourist class, claiming that a white man had a better right to the seat.
Carrascoso refused, but was eventually persuaded by other passengers to give up his
seat.
Issue:
Whether Carrascoso was entitled to a first class seat.
Whether Air France acted in bad faith.
Ruling:
The Court of Appeals found that Carrascoso had a confirmed reservation for a first
class seat and was entitled to it.
The court found that Air France's manager in Bangkok threatened Carrascoso and
forcibly ejected him from his first class seat, which constituted bad faith.
Air France was ordered to pay Carrascoso damages and attorney's fees.
Ratio:
The court emphasized the importance of adhering to the ticket issued and the need
for stability in the relations between passenger and air carrier.
The court found that Carrascoso had a confirmed reservation for a first class seat
and was entitled to it, regardless of seat availability.
Air France's manager in Bangkok threatened Carrascoso and forcibly ejected him
from his first class seat, which constituted bad faith.
Air France failed to prove that the white man who took Carrascoso's seat had a
better right to it.
Air France's actions constituted a violation of a public duty and a case of quasi-delict.
The court awarded moral damages and exemplary damages, as Air France acted in a
wanton, fraudulent, reckless, oppressive, or malevolent manner.
The amounts awarded by the trial court and the Court of Appeals were deemed
reasonable.
Airlines should treat passengers with kindness, respect, and due consideration.
Regino vs. Pangasi Colleges of Science and Technology
A first-year computer science student files a complaint for damages against her
college and teachers after being denied the opportunity to take her final exams for
refusing to purchase tickets to a fundraising event, leading to a court ruling that the
principle of exhaustion of administrative remedies does not apply in this case and
that the Commission on Higher Education does not have exclusive jurisdiction over
actions for damages based on the violation of the school-student contract.
Facts:
Petitioner, Khristine Rea M. Regino, was a first-year computer science student at
Pangasinan Colleges of Science and Technology (PCST).
PCST held a fundraising event called the "Rave Party and Dance Revolution" and
required each student to purchase two tickets for the event.
Regino refused to purchase the tickets due to financial constraints and religious
beliefs.
As a result, her teachers, Rachelle A. Gamurot and Elissa Baladad, denied her the
opportunity to take her final exams in logic and statistics.
Regino filed a complaint for damages against PCST, Gamurot, and Baladad, seeking
compensation for the violation of her rights.
Issue:
Whether the principle of exhaustion of administrative remedies applies in a civil
action exclusively for damages based on the violation of human relation provisions.
Whether there is a need for prior declaration of invalidity of a certain school
administrative policy by the Commission on Higher Education (CHED) before a
former student can successfully maintain an action exclusively for damages in
regular courts.
Whether the CHED has exclusive original jurisdiction over actions for damages based
upon violation of the school-student contract.
Ruling:
The court ruled in favor of the petitioner.
Ratio:
The principle of exhaustion of administrative remedies does not apply in this case
because the petitioner is seeking damages, which is beyond the jurisdiction of the
CHED and falls within the jurisdiction of the courts.
The principle of exhaustion of administrative remedies requires that administrative
remedies be exhausted before resorting to judicial action.
However, in this case, the petitioner is seeking damages, which is a civil action that
falls within the jurisdiction of the courts and not the CHED.
The CHED does not have the authority to award damages, making the exhaustion of
administrative remedies unnecessary.
There is no need for a prior declaration of invalidity of a school administrative policy
by the CHED before a former student can file a civil action for damages. The court
has jurisdiction over cases involving the violation of human relation provisions.
The court has jurisdiction over cases involving the violation of human relation
provisions, even without a prior declaration of invalidity by the CHED.
The CHED's authority is limited to educational policies and regulations, and it does
not have the power to declare the invalidity of a school administrative policy in a
civil action for damages.
Therefore, a former student can file a civil action for damages without the need for a
prior declaration of invalidity by the CHED.
The CHED does not have exclusive original jurisdiction over actions for damages
based on the violation of the school-student contract. The court recognized that the
school-student relationship is contractual in nature and that the school has an
obligation to provide education and observe its rules and regulations. The imposition
of additional fees or requirements not specified in the contract is a breach of
contract. The court also acknowledged that the school can be held liable for tort
even if there is an existing contract, as the act that violates the contract may also be
a tort.
The court recognized that the school-student relationship is contractual in nature,
and the school has an obligation to provide education and observe its rules and
regulations.
The imposition of additional fees or requirements not specified in the contract is a
breach of contract.
The court also acknowledged that the school can be held liable for tort even if there
is an existing contract, as the act that violates the contract may also be a tort.
Therefore, the CHED does not have exclusive original jurisdiction over actions for
damages based on the violation of the school-student contract. The court has
jurisdiction over such cases.
Batangas Laguna Tayabas Bus Co. vs. Court of Appeals
A bus company employee wrongfully dismissed without due process sues his
employer for retirement and separation benefits, leading to a Supreme Court ruling
in favor of the employee and ordering the employer to pay retirement benefits,
termination pay, and other damages.
Facts:
Teotimo de Mesa, an employee of Batangas Laguna Tayabas Bus Company, was
wrongfully dismissed from his job without due process.
De Mesa filed a lawsuit against his employer to recover his retirement and
separation benefits, loss of would-be earnings, social security benefits, damages,
attorney's fees, and costs.
The trial court found that De Mesa's dismissal was justified, except for the payment
of retirement benefits.
Both parties appealed to the Court of Appeals, which modified the trial court's
decision.
Issue:
Whether or not De Mesa's dismissal was justified and whether he is entitled to
retirement benefits.
Ruling:
The Supreme Court ruled in favor of De Mesa, stating that his dismissal was arbitrary
because the principle of due process was not observed.
The court ordered the Batangas Laguna Tayabas Bus Company to pay De Mesa
retirement benefits, termination pay with interest, and attorney's fees.
Ratio:
The court found that the employee's conduct did not constitute willful disobedience,
as the rules and instructions regarding cash advances did not pertain to his duties.
The court noted that the employee was not given a hearing on the cause of his
dismissal, in violation of the company's Service Manual and the Labor Agreement.
The court determined that the penalty of dismissal was not among the imposable
penalties prescribed in the Table of Penalties.
The court concluded that De Mesa was entitled to both termination and retirement
benefits, as neither the Termination Pay Law nor the Labor Agreement prohibited
simultaneous recovery of these benefits.