Achevara v. Ramos, G.R. No.
175172, September 29, 2009
FACTS:
On April 22, 1995, a vehicular accident occurred along the national highway in Ilocos Sur,
resulting in the death of Arnulfo Ramos. Arnulfo was driving an owner-type jeep when it
collided with a passenger jeep driven by Benigno Valdez and owned by Cresencia Achevara.
Elvira Ramos, the wife of Arnulfo, along with her two minor children, filed a complaint for
damages against Cresencia Achevara (as the jeep operator), Alfredo Achevara (her husband and
administrator of conjugal property), and Benigno Valdez (the driver), alleging negligence. The
respondents claimed Valdez drove recklessly, causing the jeep to encroach on the opposite lane.
The petitioners countered that Arnulfo's jeep was mechanically defective and swerved into their
lane. Evidence presented indicated that Arnulfo was aware of the jeep's mechanical issues prior
to the accident.
PROCEDURAL HISTORY:
The Regional Trial Court (RTC) of Ilocos Sur ruled in favor of the respondents, finding the
petitioners solidarily liable for damages based on the doctrine of last clear chance and the failure
of the Achevaras to exercise due diligence in the selection and supervision of Valdez. The Court
of Appeals (CA) affirmed the RTC decision with modifications, reducing the amounts awarded
for moral damages and attorney's fees, deleting the awards for exemplary damages and costs of
litigation, but adding an indemnity for death. The petitioners then appealed to the Supreme
Court.
ISSUE(S):
1. Are the petitioners liable to the respondents for damages resulting from the vehicular
accident?
2. Does the doctrine of last clear chance apply to the facts of this case?
3. Was the negligence of Arnulfo Ramos the proximate cause of the accident?
HOLDING:
No, the petitioners are not liable for damages. The Supreme Court reversed the Court of Appeals'
decision, holding that the negligence of both Arnulfo Ramos and Benigno Valdez contributed to
the accident, and because Ramos' negligence was a proximate cause, the respondents cannot
recover damages.
REASONING:
The Supreme Court found that the testimony of the respondents' witness was unreliable and
contradicted by other evidence. The Court determined that Arnulfo Ramos was grossly negligent
in knowingly driving a mechanically defective vehicle on the highway, creating a risk to himself
and others. Benigno Valdez was also negligent in failing to take immediate precautions upon
seeing the wiggling vehicle. The Court ruled that the doctrine of last clear chance did not apply
because Valdez did not have a reasonable opportunity to avoid the collision after Ramos' jeep
encroached on his lane. Article 2179 of the Civil Code states that when the plaintiff's negligence
is the immediate and proximate cause of the injury, they cannot recover damages. Since both
parties were negligent, and Ramos' negligence was a proximate cause, the respondents could not
recover.
RULE OF LAW:
When a plaintiff's negligence is a proximate cause of their injury, they cannot recover damages
from a negligent defendant. The doctrine of last clear chance does not apply when the defendant
does not have a reasonable opportunity to avoid the accident after the plaintiff's negligence
becomes apparent.
SIGNIFICANCE:
This decision clarifies the application of the doctrine of last clear chance and reinforces the
principle that a plaintiff's own negligence, if a proximate cause of the injury, bars recovery of
damages. It highlights the importance of exercising reasonable care and caution when operating a
vehicle, especially when known defects exist.
KEYWORDS:
Negligence, Proximate Cause, Last Clear Chance, Contributory Negligence, Damages, Vehicular
Accident, Civil Code Article 2179, Foreseeability, Gross Negligence, Inexcusable Negligence
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