In a ruling concerning the obligations of common carriers, the Supreme Court affirmed that bus companies are presumed negligent when passengers sustain injuries. This decision underscores the high standard of care expected from public transportation providers, reinforcing their responsibility to ensure passenger safety. It also highlights the importance of extraordinary diligence in preventing accidents and the consequences of failing to meet this duty.

When a Bus Trip Turns Treacherous: Examining a Common Carrier’s Duty of Care

This case, R Transport Corporation v. Eduardo Pante, revolves around a bus accident where a passenger, Eduardo Pante, sustained injuries when the R Transport Corporation bus he was riding hit a tree and a house. The incident occurred in Baliuag, Bulacan, on January 27, 1995, while Pante was en route from Cubao, Quezon City, to Gapan, Nueva Ecija. The central legal question is whether R Transport Corporation, as a common carrier, is liable for the injuries Pante sustained due to the negligence of its bus driver. This decision reaffirms the high standard of care expected from common carriers under Philippine law.

Under the Civil Code, common carriers are obligated to exercise extraordinary diligence for the safety of their passengers. This requirement stems from the nature of their business and public policy considerations. The Civil Code emphasizes this duty in Article 1733:

Common carriers, from the nature of their business and for reasons of public policy, are bound to observe extraordinary diligence in the vigilance over the goods and for the safety of the passengers transported by them, according to all the circumstances of each case.

Further clarifying this obligation, Article 1755 states:

A common carrier is bound to carry the passengers safely as far as human care and foresight can provide, using the utmost diligence of very cautious persons, with due regard for all the circumstances.

Building on these provisions, Article 1756 establishes a presumption of negligence against common carriers in cases involving passenger injury:

In case of death of or injuries to passengers, common carriers are presumed to have been at fault or to have acted negligently, unless they prove that they observed extraordinary diligence as prescribed by Articles 1733 and 1755.

This presumption places the burden on the common carrier to prove they exercised extraordinary diligence. Article 1759 further reinforces this liability, holding common carriers responsible for the negligence or willful acts of their employees, even if those acts are beyond the scope of their authority. Critically, this liability exists regardless of whether the carrier exercised diligence in the selection and supervision of its employees.

In this case, the Court found that R Transport Corporation failed to overcome the presumption of negligence. The evidence showed the bus driver’s reckless driving directly caused the accident and Pante’s resulting injuries. The fact that the bus hit a tree and a house was concrete proof of negligence on the part of the driver. Moreover, the Court rejected R Transport’s argument that it was denied due process, noting the numerous opportunities it had to present evidence, which it repeatedly failed to do. The petitioner’s repeated absences and motions for postponement led to a waiver of their right to present evidence.

The Court also upheld the awards for actual, moral, and exemplary damages. Actual damages were awarded based on the hospital statement of account, which the Court deemed admissible as evidence. Moral damages were justified due to the physical pain, mental anguish, and anxiety Pante suffered as a result of the accident. The award of exemplary damages was supported by evidence of the bus driver’s reckless driving, intended to serve as a deterrent to similar behavior in the future. In the end, the award of attorney’s fees, constituting 25% of the total amount, was considered justified considering the seven year journey taken at the trial court.

FAQs

What was the key issue in this case?	The key issue was whether R Transport Corporation, as a common carrier, was liable for the injuries sustained by Eduardo Pante due to the negligence of its bus driver. The court needed to determine if the bus company met the required standard of extraordinary diligence.
What standard of care is required of common carriers in the Philippines?	Common carriers in the Philippines are required to exercise extraordinary diligence for the safety of their passengers. This high standard of care is mandated by the Civil Code, reflecting the public’s reliance on these services.
What happens if a passenger is injured while on a common carrier?	If a passenger is injured, the common carrier is presumed to have been at fault or to have acted negligently. The burden then shifts to the carrier to prove that it observed extraordinary diligence.
Can a common carrier avoid liability by proving diligence in hiring and supervising employees?	No, even if a common carrier proves it exercised diligence in the selection and supervision of its employees, it is still liable for the negligence or willful acts of those employees that cause passenger injury. The carrier has a higher burden to ensure safety.
What types of damages can be awarded to an injured passenger?	An injured passenger may be awarded actual damages (e.g., medical expenses), moral damages (for pain and suffering), and exemplary damages (as a deterrent). These damages aim to compensate the passenger for the harm suffered and prevent future negligence.
Is a hospital statement of account sufficient evidence for claiming actual damages?	Yes, the court held that a hospital statement of account is admissible evidence of hospital expenses incurred by the injured passenger. A formal receipt is not necessarily required, if a valid and detailed statement exists.
Why was R Transport Corporation found liable in this case?	R Transport Corporation was found liable because it failed to prove that it observed extraordinary diligence in ensuring the safety of its passengers. The driver’s negligence resulted in the injuries sustained by Pante, and it failed to appear to its scheduled hearings and present its defense.
What is the significance of this case for bus companies in the Philippines?	This case reinforces the high standard of care expected from bus companies and other common carriers. It serves as a reminder of their responsibility to prioritize passenger safety and the potential consequences of failing to do so.
Can a passenger recover attorney’s fees in a successful claim against a common carrier?	Yes, in this case, the Court upheld the award of attorney’s fees to the respondent’s counsel, amounting to 25% of the total damages awarded. This reflects the effort required to secure redress for the injured party.

This case serves as a critical reminder to common carriers in the Philippines of their significant responsibility to ensure passenger safety through extraordinary diligence. The ruling not only provides recourse for victims of negligence but also sets a clear standard that aims to improve safety and accountability within the public transportation sector.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: R TRANSPORT CORPORATION VS. EDUARDO PANTE, G.R. No. 162104, September 15, 2009