Sydeco vs.

People: Sydeco was charged with driving under the influence of liquor and resistance and
disobedience to a person in authority, committed against police Officer Aguilar when he was
apprehended on Roxas Blvd, and pushed and shoved the same against the pavement. Sydeco on appeal,
set up the defense that the Officer attempted to rob and injure him. The court held in favor of Sydeco,
finding irregularity in the performance of the Police Officer’s duties. Upon seeing Sydeco driving his
vehicle in a swerving manner, and the officers seeing three empty beer cases inside, they immediately
concluded that Sydeco was driving under the influence, and ordered them to step out for a search. TO
avoid the unreasonable search, Sydeco uttered his “Plain View Search” defense, pissing the police
officer’s off, and triggering the confrontation. All of this was done without the officers asking for license
and registration before asking them to step out, as required by RA4136. Furthermore, RA4136’s
definition of Reckless driving does not include the element of swerving, since the same is not
immediately indicative of such. Hence, the offenses charged cannot be granted since there was
irregularity in the performance of the persons in authority.

Adzuara vs. CA: Adzuara was charged with Reckless Imprudence resulting to Damage Against Property
with Less Serious Physical Injuries. At 1:00 am, while Adzuara was driving his Colt Galant along EDSA
towards Delta Circle, he collided with Martinez’s Toyota Corola while the latter was making a U-Turn.
Adzuara contests his conviction, but the court held that he was guilty based on the findings of fact by
the RTC. The left turn sign was green when Martinez attempted to make the U-turn, but Adzuara hit him
on the left, meaning that the right of way was with Martinez. There were also no skid marks to show
that Martinez made a swift U-turn, and Adzuara was not in sight when Martinez attempted to make the
turn, though suddenly he was hit, meaning that Adzuara was driving quickly. What degree of care and
vigilance then did the circumstances require? At half past 1:00 o’clock in the morning along an almost
deserted avenue, ordinary care and vigilance would suffice. This may consist of keeping a watchful eye
on the road ahead and observing the traffic rules on speed, right of way and traffic light. It is a rule that
a motorist crossing a thru-stop street has the right of way over the one making a U-turn. But if the
person making a U-turn has already negotiated half of the turn and is almost on the other side so that
he is already visible to the person on the thru-street, the latter must give way to the former. Petitioner
was on the thru- street and had already seen the Martinez car. He should have stopped to allow
Martinez to complete the U-turn having, as it were, the last clear chance to avoid the accident which he
ignored. In fact, he never stopped. Hence, the negligence falls to Adzuara.

Marikina Auto Line Transport Corporation vs. People: Suelto, employee of MALTC, while he was driving
a bus along EDSA, swerved to the right and hit the terrace of an apartment owned by Vandellon.
Vandellon demanded payment of damages, which petitioners refused based on the defense that the
swerving was made to avoid a collision, applying the sudden-emergency rule. The court held that the
sudden-emergency rule cannot apply, pursuant to Article 2185 of the Civil Code, which provides that a
driver is presumed negligent if at the time of the mishap, he was violating any traffic regulation, unless
there is proof to the contrary. As admitted and in support of their defense, Suelto admitted that he
violated the Land Transportation and Traffic Code for swerving a bus to the right. However, they failed
to prove that there was another car, further shown by their failure to file a case against the third-party.
The burden of proof when applying the sudden-emergency rule falls on the claimant. In this case, the
petitioners failed to overcome the presumption of negligence.

Mallari vs. CA: Mallari Jr., who was driving a Jeepney 5:00 in the morning, collided with a Van driven by
an employee of Bulletin Publishing, while the former was about to make an overtake, and the latter
whom the former saw coming from the opposite direction, hit him, causing the Jeep to fall on its left,
killing one of its passengers. The victim’s family filed for damages against both parties, and the
proximate casue was attributed to Mallari. The court held that the proximate cause was with Mallari
given that he already admitted that he saw the van coming from the opposite direction, but still pursued
the overtake. The rule is settled that a driver abandoning his proper lane for the purpose of overtaking
another vehicle in an ordinary situation has the duty to see to it that the road is clear and not to proceed
if he cannot do so in safety. When a motor vehicle is approaching or rounding a curve, there is special
necessity for keeping to the right side of the road and the driver does not have the right to drive on the
left hand side relying upon having time to turn to the right if a car approaching from the opposite
direction comes into view.

Pestano vs. Sumayang: Sumayang and Romagos were hit by a passenger bus driven by Pestano and
owner by Metro Cebu Autobus, when the latter attempted to overtake their motorcycle at a junction.
The victims died, causing the institution of criminal and civil cases. The court held that Pestano was
negligent. As a professional driver operating a public transport bus, he should have anticipated that
overtaking at a junction was a perilous maneuver and should thus have exercised extreme caution.
There is a presumption of negligence on the part, not only on the driver, but also the employer in the
selection and supervision of employees. The fact that the speedometer of the driver was broken, which
indirectly assisted in the accident, shows the negligence in supervision of the owners, who have the duty
to make sure that their buses were optimal, and should not have allowed an employee to drive a vehicle
with defect.

Kapalaran Bus Line vs. Coronado: A Jeepney driven by Grajera was hit on its right side by a bus owned
by Kapalaran. The Bus, according to its route, was supposed to cross the town of Pila Laguna, but instead
proceeded to take the National HW given that it already had full capacity. It saw that two cars were
stopped in front of it, so it overtook at a fact speed just as the Jeep was crossing on the intersection
from another National HW. The bus failed to stop, and hit the jeep right at its path. Cases for damages
were filed against Kapalaran. The court held that the bus driver was negligent. At the speed it was going,
it violated RA4136 on Restrictions as to speed, raising the presumption on negligence given that at the
time of the mishap, he was violating traffic regulations. The Jeepney’s act of entering the intersection
was not negligence for he had the right to assume that no cars would come overtaking from the
opposite direction, seeing that the bus was still far away. It was the duty of the overtaking vehicle to
ensure that the road was clear.

Mirasol vs. DPWH: Petitioners seek the nullity of several DPWH issuances for violating and being
inconsistent with RA2000, or the Limited Access Highway Act. The court held the issues separately, thus:

1. The issuance giving the DPWH authority to determine who can use toll ways, which are limited
access facilities, are void. RA2000 limits the authority of the DPWH to redesigning tollgates and
other entrances to limited access facilities. The DPWH does not have the authority to declare
certain express ways as limited access facilities. It is the DOTC which is given such authority over
Limited access facilities.
2. On the issuance prohibiting non-motorized vehicles from entering limited access facilities, such
is a reasonable exercise of police power to ensure public safety on the roads. It refers to the
highways inside limited access facilities themselves, so the DPWH has authority. A toll way is not
an ordinary road. As a facility designed to promote the fastest access to certain destinations, its,
 operation, and maintenance require close regulation. Public interest and safety require the
imposition of certain restrictions on toll ways that do not apply to ordinary roads. As a special
kind of road, it is but reasonable that not all forms of transport could use it. Right to travel is not
violated because this right does not refer to the choice of vehicle, but refers to the act of going
from one place to another.

Valmonte vs. De Villa: Petitioners seek reversal of the 1989 decision of the court, which declared that
checkpoints are not illegal per se. Thus, under exceptional circumstances, as where the survival of
organized government is on the balance, or where the lives and safety of the people are in grave peril,
checkpoints may be allowed and installed by the government. Implicit in this proposition is, that when
the situation clears and such grave perils are removed, checkpoints will have absolutely no reason to
remain. The court maintained its ruling. One must concede to it the basic right to defend itself from its
enemies and, while in power, to pursue its program of government intended for public welfare; and in
the pursuit of those objectives, the government has the equal right, under its police power, to select the
reasonable means and methods for best achieving them. The checkpoint is evidently one of such means
it has selected. Admittedly, the routine checkpoint stop does intrude, to a certain extent, on motorist’s
right to “free passage without interruption”, but it cannot be denied that, as a rule, it involves only a
brief detention of travellers during which the vehicle’s occupants are required to answer a brief
question or two. For as long as the vehicle is neither searched nor its occupants subjected to a body
search, and the inspection of the vehicle is limited to a visual search, said routine checks cannot be
regarded as violative of an individual’s right against unreasonable search.

LTO vs. Butuan City: The court is asked in this case to resolve the issue of whether under the present set
up the power of the Land Registration Office (“LTO”) to register, tricycles in particular, as well as to issue
licenses for the driving thereof, has likewise devolved to local government units. The court held that the
LTO still maintains its authority for the registration and licensing of the vehicles. What the LGC delegates
to the LGU’s is the power of the LTFRB to issue franchises and CPC’s, and the regulatory power over
common carriers and vehicles. They are different under existing laws. Art. 468 of the LGC shows this
delegation of power, subject to guidelines prescribed by the DOTC, which was complied with by the
latter. The law governing the LTO is RA4136, while the LTFRB is of EO202.

PNR vs. CA (1985): PNR seeks the reversal of the CA’s decision holding it liable for the death of a
passenger who fell of their train. PNR opposes this by invoking state immunity from suit, alleging that it
is a mere agency of the PH government without distinct personality of its own, and that its funds are
governmental in character and, therefore, not subject to garnishment or execution. The court held that
they are not immune. By virtue of RA4156, creating the PNR, Sec. 2 provides that the PNR shall exercise
all powers of a corporation under the Corporation Law. Hence, it is a personality that can sue and be
sued. Also, PNB vs. CIR already held that the funds, being public in character, does not mean that it is
not susceptible to garnishment or execution, given that this agency’s have a personality of their own,
distinct from the government. The passenger dies due to allowing the victim to board the train despite
being overcrowded already, though the victim is also liable for contributory negligence for sitting by the
railings of an open platform.

PNR vs. CA (2007): A PNR train hit Amores while he was intersecting the railroad in his car, where the
latter was dragged 10 meters away and died as a consequence. The victim’s family seeks damages
against PNR. The court held that PNR was negligent for running at a fast speed as it approached an
intersection, evidenced by the dragging of the vehicle 10 meters away. They were also negligent in
informing the public at their crossings for lack of a cross bar and a flag man, not just a mere dilapidated
Stop, Look, and Listen Sign. As held in PNR vs. Brunty, railroad companies owe to the public a duty of
exercising a reasonable degree of care to avoid injury to persons and property at railroad crossings,
which duties pertain both to the operation of trains and to the maintenance of the crossings. Moreover,
every corporation constructing or operating a railway shall make and construct at all points where such
railway crosses any public road, good, sufficient, and safe crossings, and erect at such points, at
sufficient elevation from such road as to admit a free passage of vehicles of every kind, a sign with large
and distinct letters placed thereon, to give notice of the proximity of the railway, and warn persons of
the necessity of looking out for trains. Public Safety requires its installation despite no law requiring it. In
addition, it is true that motorists must use their faculties of senses when nearing railroad crossing, but
the case shows that Amores acted with absolute case and caution, shown by his act of slowing and
stopping just before the crossing. Regardless, the issue here is the fact that there was negligence for
failure to install cross bars and flagmen to warn the public.

Erezo vs. Jepte: A 6by6 truck owned by Jepte collided with a taxicab driven by Erezo at an intersection in
Manila. Jepte’s defense is that the true owners of the truck was really Port Brokerage, and that they
were registered under his name so as to enable the corporation to pay the registration fee with his
backpay as a prewar government employee. The heirs demand damages. The court held that the
registered-owner rule applies. The Revised Motor Vehicle Law shows the purpose of Registration, not as
evidence of ownership, but as a way to identify and fix responsibility to one person when an accident or
damage is incurred to another, that is, to the registered owner. Hence, Jepte is liable for the accident,
though this is without prejudice to his right to institute a third party action against Port Brokerage if
there indeed was a valid agreement between the two.

Metro Manila Transit Corporation vs. Cuevas: MMTC entered into an agreement with Mina’s Transit,
where the former would sell its bus units to the latter, but MMTC would retain ownership of the units
until certain conditions are met, and Minas would be allowed to operate them in the meantime. Cuevas,
the vehicular accident victim of one the buses after the sale, filed a case against both for damages.
Pursuant to Art. 2180 holding employers to be solidarily liable to his employees, both MMTC and Minas
were found liable for the damages. MMTC opposed this, but the court held that the registered-owner
rule applies in this case, whereby the registered owner of the motor vehicle involved in a vehicular
accident could be held liable for the consequences. This rule has been held good law in Erezo vs. Jepte.
The agreement between the parties does not bind third parties, who could only rely on the name stated
in the registration certificate. But pursuant to the agreement, the cross-claim of MMTC should be
granted.

Aguilar Sr. vs. Commercial Savings Bank: Aguilar Jr. was the victim of a vehicular accident involving a
Lancer driven by Borja and registered under the Bank’s name, causing the death of the Aguilar Jr. Aguilar
Sr. seeks damages. The court held that the registered-owner rule applies, where an EER is immaterial. As
held in Ba Finance vs. CA, the rule applies to any vehicle, even if it is not for Public Service. The ratio in
Erezo as to the purpose of Registration applies.

Equitable Leasing Corp. vs. Suyom: Equitable Leasing Corp issued a deed of sale to Ecatine for a Tractor,
but the sale was not registered with the LTO. Tutor, employee of Ecatine, then recklessly drove the
tractor through the house of the respondents, killing and injuring many of them. The injured and heirs
then filed criminal and civil cases against the driver and registered owner. The criminal case did not
prosper, hence the victims pursued a civil case of Quasi Delict. The court held that the registered rule
applies. The finance-lease agreement between Equitable on the one hand and Lim or Ecatine on the
other has already been superseded by the sale. In any event, it does not bind third persons. In this case,
the registered owner of the tractor is considered under the law to be the employer of the driver, while
the actual operator is deemed to be its agent, for the application Art. 2180. Thus, Equitable, the
registered owner of the tractor, is—for purposes of the law on quasi delict—the employer of Raul Tutor,
the driver of the tractor. Ecatine, Tutor’s actual employer, is deemed as merely an agent of Equitable.
Also, the non-registration of the vehicle is the fault of Equitable, hence it must face the legal
consequences thereof.