The Supreme Court denied the appeal of Danilo Agpoon and Mark Laza and affirmed that they are jointly and severally liable to pay Standard Insurance Co., Inc. PHP 270,509.42 in actual damages for a vehicular accident in Bauang, La Union. The Court found that Agpoon was negligent and that his negligence was the proximate cause of the damage to the insured vehicle.
The Case
The vehicles involved were a Honda CR-V bearing Plate No. AHJ 778 owned and driven by Peter Paul Nang, and a Toyota Innova bearing Plate No. RNU 254 driven by petitioner Danilo Agpoon. Petitioner Mark Laza was the registered owner of the Innova. Respondent Standard Insurance Co., Inc. is the insurer of Nang's CR-V under Insurance Policy Schedule No. BG-PCV-200050997.
On December 6, 2016, Standard Insurance filed a complaint for recovery of sum of money based on quasi-delict against Laza and Agpoon. It alleged that it was the insurer of the CR-V; that while travelling along the National Highway of Barangay Urayong, Bauang, La Union Province on November 6, 2014, the Innova hit the CR-V; that by virtue of the insurance contract, Standard Insurance paid Nang's property damage claim in the amount of PHP 270,509.42; and that as the lawful subrogee of Nang's right, it demanded reimbursement from Laza and Agpoon, who refused to pay.
Laza and Agpoon countered that it was Nang who was negligent when he made a sudden U-turn on a national highway without due regard to the road's condition. They prayed for the dismissal of the complaint and interposed a compulsory counterclaim for damages amounting to PHP 116,208.86.
The two sides presented opposing versions of the accident. Laza and Agpoon claimed Agpoon was returning to his lane after overtaking a vehicle when the CR-V made a sudden U-turn across the road. Standard Insurance argued that Nang had turned on his left signal light and had already occupied a substantial portion of the opposite lane, with a Nissan Sentra slowing down and blinking its headlights to give way, when the Innova overtook the Sentra on its right shoulder and hit the CR-V.
The Issue
The question before the Court was whether Standard Insurance was able to substantiate and prove its claim based on quasi-delict against Laza and Agpoon, and whether Agpoon's negligence was the proximate cause of the damage to the insured CR-V.
The Ruling
The Court ruled that Standard Insurance was able to substantiate and prove its claim based on quasi-delict. It found that the CR-V sustained damages as a result of the incident; that Agpoon was at fault and negligent, as he himself admitted he was overtaking a vehicle; and that Agpoon's negligence was the proximate cause of the damage sustained by Nang's CR-V.
The Court sustained the award of damages based on Article 2176 of the Civil Code, and Laza's vicarious liability as Agpoon's employer pursuant to Article 2180 of the same Code. It held that petitioners are jointly and severally liable to pay PHP 270,509.42 as actual damages, PHP 30,000.00 as attorney's fees, and legal interest at the rate of 6% per annum.
In its disposition, the Court declared: "ACCORDINGLY, the Petition for Review on Certiorari is DENIED. The Decision of the Court of Appeals dated May 10, 2024 and its Resolution dated April 4, 2025 in CA-G.R. SP No. 175939 are AFFIRMED."
By the Numbers
- Date of accident: November 6, 2014, at around 8:30 a.m.
- Date complaint filed: December 6, 2016
- Property damage claim paid to Nang: PHP 270,509.42
- Actual damages ordered paid: PHP 270,509.42
- Counterclaim of Laza and Agpoon: PHP 116,208.86
- Amount Laza and Agpoon offered to pay Nang directly: PHP 200,000.00
- Attorney's fees awarded: PHP 30,000.00
- Legal interest: 6% per annum
- CA Decision: May 10, 2024; CA Resolution: April 4, 2025
- Docket: CA-G.R. SP No. 175939; G.R. No. 279772
The Court's Reasoning
The Court defined negligence as the failure to observe for the protection of the interests of another person that degree of care, precaution, and vigilance which the circumstances justly demand, by reason of which such other person suffers injury. It stated that the test is whether the defendant used reasonable care and caution which an ordinary person would have used in the same situation.
On the argument that Nang was violating Sections 42(a) and 44(a) of the Land Transportation and Traffic Code, Republic Act No. 4136, the Court approved the disquisition of the Court of Appeals. It noted that the statutory right of way rule applies only where vehicles are approaching the intersection at approximately the same time, and that a motorist on a thru-street must give way to a person making a U-turn who has already negotiated half of the turn and is visible. The Court found that Nang was not violating the rule on right of way, as it was sufficiently established that in making the turn he had already occupied a substantial portion of the opposite lane, manifested by the fact that the Sentra blinked its headlights to give way.
On the claim that Nang failed to signal before turning, the Court held that Laza and Agpoon proffered no other evidence to substantiate the claim, stressing that mere allegation is not evidence and not equivalent to proof.
Source: Supreme Court Decision in G.R. No. 279772.
This report summarizes a public Supreme Court decision and is not legal advice.