Robles v. People

 

Robles v. People

G.R. No. 223810

August 2, 2023

 

FACTS:

A vehicular collision happened between a Yamaha motorcycle driven by Ronelo and a Suzuki motorcycle driven by accused Robles. The prosecution alleged that Ronelo, upon reaching the intersection, a speeding Suzuki Motorcycle suddenly crossed and caused the collision of the two motorcycles. He alleged that Robles had no driver’s license and his motorcycle had no plate. On the other hand, the version of the defense was that at the intersection, Robles signaled to turn left but Ronelo suddenly came from behind and attempted to overtake him, causing the collision. Robles offered in evidence pictures showing the damages to his motorcycle, which were all on its left side. Further, Ronelo’s attending physician testified that based on Ronelo’s admitting notes, history, and examination with the latter, Ronelo was drunk when he drove his motorcycle during which he collided with another motorcycle. PO3 Maulas, also testified and based on his police report and sketch, both were travelling in the same direction, heading north, contrary to the prosecution’s evidence that Robles came speeding from Calceta Street. Robles was ahead at the intersection, made a signal to the left to turn, and the speeding motorcycle of Ronelo suddenly overtook the left side, resulting in the collision. The MTCC, RTC, and CA found Robles guilty of the charge.

ISSUE:

Whether or not Robles is negligent under Art. 2185 of the Civil Code.

HELD:

No. In order to establish a motorist's liability for the negligent operation of a vehicle, it must be shown that there was a direct causal connection between such negligence and the injuries or damages complained of. Mere negligence will not suffice because it is the motorist's willful and wanton act done in utter disregard of the consequence of his or her action, which criminalizes an imprudent or negligent act Pursuant to Article 2185 of the Civil Code, the complainant must nevertheless show that the violation of the statute was the proximate or legal cause of the injury, or that it substantially contributed thereto. Here, Robles could not be presumed negligent, considering that there is no causal connection that could be reasonably drawn between his violations – lack of driver’s license and driving an unregistered vehicle – and the proximate cause of the accident. Additionally, there is no evidence that the violation contributed to the accident. Hence, that Robles only had a student driver's permit could not at the onset give rise to a presumption that he was negligent, considering that the Traffic Code explicitly allows a student driver to operate a motor vehicle when accompanied by a duly licensed driver. In addition to that, the doctrine of last clear chance states that where both parties are negligent but the negligent act of one is appreciably later than that of the other, or where it is impossible to determine whose fault or negligence caused the loss, the one who had the last clear opportunity to avoid the loss but failed to do so is chargeable with the loss.