This case dwells on the doctrine of res ipsa loquitur and its applicability to vehicular accidents. What is res ipsa loquitur?
Res ipsa loquitur is literally translated as “the thing or the transaction speaks for itself”. The doctrine res ipsa loquitur means that “where the thing which causes injury is shown to be under the management of the defendant, and the accident is such as in the ordinary course of things does not happen if those who have the management use proper care, it affords reasonable evidence, in the absence of an explanation by the defendant, that the accident arose from want of care”. It is simply “a recognition of the postulate that, as a matter of common knowledge and experience, the very nature of certain types of occurrences may justify an inference on the part of the person who controls the instrumentality causing the injury in the absence of some explanation by the defendant who is charged with negligence. It is grounded in the superior logic of ordinary human experience and on the basis of such experience or common knowledge, negligence may be deduced from the mere occurrence of the accident itself.xxx” (Underscoring supplied). (Solidum vs People, 728 Phil. 578, 589 (2014)
In this case, AAA, on board a vehicle driven by her driver, BBB, were driving along a common driveway when BBB sideswiped CCC, a six-year old daughter of DDD. As a result of the vehicular accident, CCC sustained injuries and underwent operation on the leg fractures she sustained and was wheelchair bound from April 25, 2006 to July 18, 2006. Because the parties failed to agree on a settlement, DDD sued AAA andBBB before the RTC for damages based on quasi-delict. The RTC ruled in favor of DDD, and held AAA and BBB liable. AAA appealed all the way to the Supreme Court, which however, denied her appeal.In finding her liable, the High Court applied the doctrine of res ipsa loquitur. Citing the case of UCPB General Insurance Co. v. Pascual Liner Inc. (G.R. No. 242238, April 26, 2021), which reiterated the applicability of res ipsa loquitur in vehicular accidents, and once established, through the admission of evidence, whether hearsay or, the rule on res ipsa loquitur starts to apply, the Court ruled that the fact that CCC’s injuries was sustained in a collision with AAA’s vehicle, clearly established that a vehicular accident happened that caused injuries, and the rule on res ipsa loquitur shall apply. An inference of negligence arose on the part of BBB, the one who was driving the vehicle and who controls the instrumentality causing the injury, and he thus has the burden of presenting proof to the contrary. AAA and BBB’s defense that they were driving slowly in a common driveway are belied by the fact that CCC sustained injuries necessitating her to be in a wheelchair for several months:
“Ordinarily driving inside a relatively narrow driveway shared by two houses would not result to children being hit and their bones fractured. This is because a reasonably prudent man, especially an alleged experienced driver, would have foreseen that the residents of the houses may exit towards the common driveway anythime, including young and playful children who may suddenly run across or along said driveway. Thus, a reasonably prudent man is expected to drive with utnost caution when traversing the said driveway, even if given a “clear” signal by the guard.”
JESSICA P. MAITIM a.ka. “JEAN GARCIA” vs. MARIA THERESA P. AGUILA, G.R. No. 218344, March 21, 2022