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Raynera vs. HicetaG.R. No. 120027 | April 21, 1999

FACTS:1. Petitioner Edna Raynera was the widow of Reynaldo Raynera and

the mother and legal guardian of the minors Rianna and Reianne2. Respondents Freddie Hiceta and Jimmy Orpilla were the owner and

driver respectively of an !su"u truc#$trailer involved in theaccident.

%. &arch 2% 1'(' at a)out 2am*- Reynaldo Raynera was on his way home. He was riding a

motorcycle traveling on the south)ound lane of East +ervice

Road ,upang &untinlupa.- -he !su"u truc# was travelling ahead of him at 2 to %

#ilometers per hour. -he truc# was loaded with two /20 metalsheets etended on )oth sides two /20 feet on the left and three/%0 feet on the right. -here were two /20 pairs of red lights a)out% watts each on )oth sides of the metal plates.

- -he asphalt road was not well lighted.- 3t some point on the road Reynaldo Raynera crashed his

motorcycle into the left rear portion of the truc#trailer whichwas without tail lights.

- 4ue to the collision Reynaldo sustained head in5uries and truc#helper 6eraldino 4. 7ucelorushed him to the Para8a9ue &edical

,enter.- :pon arrival at the hospital the attending physician 4r. &arivic

3guirrepronounced Reynaldo Raynera dead on arrival.;. 3t the time of his death Reynaldo was the manager of the

Engineering 4epartment o= had a life epectancy of ? y>o= annual net earnings of not lessthan P@%. Heirs of deceased demanded from respondents payment of damages

arising from the death of Reynaldo Raynera as a result of thevehicular accident

?. Respondents refused to pay the claims@. Petitioners filed with R-, &anila a complaint for damages against

respondents owner and driver of !su"u truc#- +ought recovery of damages for the death of Raynera caused )y

the negligent operation of the truc#$trailer at nighttime on thehighway without tail lights

(. Respondents*

- -ruc# was travelling slowly on the service road not par#edimproperly at a dar# portion of the road with no tail lightslicense plate and early warning device

'. -,* in favor of petitioners= found respondents negligent )ecause thetruc# had no license plate and tail lights= there were only 2 pairs ofred lights watts each on )oth sides of the steel plates= the truc#was improperly par#ed in a dar# area= the respondentsA negligencewas the immediate and proimate cause of RayneraAs death= reducedresponsi)ility of respondents )y 2B on account of victimAs ownnegligence

1. Respondents appealed to ,311. ,3* RayneraAs )umping into the left rear portion of the truc# was the

proimate cause of his death and conse9uently a)solvedrespondents from lia)ility

12. Hence this petition for review on certiorari

ISSUE: Whether or not respondents were negligent; If so, whether such

negligence was the proximate cause of the death of Reynaldo Raynera

HE!: "#

R$%I#:

CDegligence is the omission to do something which a reasona)le man guided)y those considerations which ordinarily regulate the conduct of human

affairs would do or the doing of something which a prudent and reasona)leman would not do.

Proimate cause is Cthat cause which in natural and continuous se9uence

un)ro#en )y any efficient intervening cause produces the in5ury and withoutwhich the result would not have occurred.

4uring the trial it was esta)lished that the truc# had no tail lights. -hephotographs ta#en of the scene of the accident showed that there were no taillights or license plates installed on the !su"u truc#. !nstead what wereinstalled were two /20 pairs of lights on top of the steel plates and one /10

pair of lights in front of the truc#. ith regard to the rear of the truc# thephotos ta#en and the s#etch in the spot report proved that there were no taillights.

4espite the a)sence of tail lights and license plate respondentsA truc# wasvisi)le in the highway. !t was traveling at a moderate speed approimately2 to % #ilometers per hour. !t used the service road instead of the highway

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)ecause the cargo they were hauling posed a danger to passing motorists. !ncompliance with the 7and -ransportation -raffic ,ode /Repu)lic 3ct Do.

;1%?0 respondents installed 2 pairs of lights on top of the steel plates as thevehicleAs cargo load etended )eyond the )ed or )ody thereof.

We find that the direct cause of the accident was the negligence of the

&ictim. -raveling )ehind the truc# he had the responsi)ility of avoiding)umping the vehicle infront of him. He was in control of the situation. Hismotorcycle was e9uipped with headlights to ena)le him to see what was infront of him. He was traversing the service road where the prescri)ed speedlimit was less than that inthe highway.

-raffic investigator ,pl. Girgilio del &onte testified that two pairs of watts)ul)s were on top of the steel plates which were visi)le from a distance of

1 meters.Girgilio +antos admitted that from the tricycle where he was on)oard he saw the truc# and its cargo of iron plates from a distance of ten /10

meters. !n light of these circumstances an accident could have )een easilyavoided unless the victim had )een driving too fast and did not eercise due

care and prudence demanded of him under the circumstances.

!t has )een said that drivers of vehicles Cwho )ump the rear of anothervehicle are presumed to )e Cthe cause of the accident unless contradicted

)y other evidence.-he rationale )ehind the presumption is that the driver ofthe rear vehicle has full control of the situation as he is in a position too)serve the vehicle in front of him.