Title

G.V. Florida Transport, Inc. vs. Heirs of Battung, Jr.

Case
G.R. No. 208802
Ponente
PERLAS-BERNABE, J
Decision Date
Oct 14, 2015
A common carrier is not liable for damages caused by a co-passenger's actions, as their responsibility
for passenger safety is based on negligence and not absolute guarantee.
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Facts:
 The case involves a dispute over the liability of a common
carrier for damages arising from the death of a passenger
caused by a co-passenger.
 The respondent, Romeo L. Battung, Jr., boarded the
petitioner's bus bound for Manila.
 During the trip, a man seated at the fourth row of the bus shot
Battung in the head and fled the scene.
 Battung was pronounced dead upon arrival at the hospital.
 The heirs of Battung filed a complaint for damages against the
petitioner, alleging that the petitioner and its employees failed
to exercise extraordinary diligence in ensuring the safety of
passengers.
 The Regional Trial Court (RTC) ruled in favor of the
respondents and held the petitioner, along with its employees,
jointly and severally liable for damages.
 The Court of Appeals (CA) affirmed the RTC's decision.

Issue:
 Whether or not the petitioner is liable for damages arising from
culpa contractual.

Ruling:
 The Supreme Court ruled in favor of the petitioner.

Ratio:
 The Court emphasized that common carriers are not insurers
of the absolute safety of their passengers and that their
liability for personal injuries rests upon their negligence.
 In this case, the death of Battung was caused by a co-
passenger and not due to any defect in the means of transport
or the negligence of the petitioner's employees.
 Therefore, the petitioner cannot be held liable for damages.
 The Court also clarified that the duty of a common carrier to
ensure the safety of its passengers should be balanced with
the passengers' right to privacy.
 Common carriers should be given leeway in assuming that
passengers will not bring anything dangerous on board unless
there is evidence to the contrary.