MA. LOURDES VALENZUELA vs.

COURT OF APPEALS, RICHARD LI and

ALEXANDER COMMERCIAL, INC.
G.R. No. 115024 February 10, 1996
KAPUNAN, J.:
1. Ma. Lourdes Valenzuela was driving a blue Mitsubishi lancer until she noticed something was wrong
with her tires so she stopped at a lighted place and verified it to ask for help.
2. While she was at the area where she stopped her car, she was bumped by a 1987 Mitsubishi Lancer
driven by Richard Li and registered under Alexander Commercial Inc. which resulted to her
confinement and knee amputation.
3. Plaintiff prayed for moral damages in the amount of P1 million, exemplary damages in the amount of
P100,000.00 and other medical and related expenses amounting to a total of P180,000.00, including loss
of expected earnings.
4. The trial court found Li guilty of gross negligence and liable for damages under Article 2176 of the
Civil Code while Alexander Commercial, Inc., Lis employer, was held jointly and severally liable for
damages pursuant to Article 2180
5. The Court of Appeals sustained that Li was liable for the damages but absolved Alexander Commercial
Inc., from any liability against Valenzuela.
6. Richard Li, in a separate petition, contends that he should not be held liable for damages because the
proximate cause of the accident was Ma. Lourdes Valenzuelas own negligence.
ISSUE:
Whether or not Li shall be held liable for the damages
RULING:
Yes. Li shall be held liable for the damages pursuant to Article 1162 which provides that Obligations
derived from quasi-delicts shall be governed by the provisions of Chapter 2, Title XVII of this Book,
and by special laws.
Negligence is commonly understood as the conduct which creates an undue risk of harm to others. The
circumstances established by the evidence showed that Li was grossly negligent in driving the Mitsubishi
Lancer. It was emphasized that he was driving at a fast speed at 2AM after a heavy downpour which made
the street slippery. There was also ample evidence showing that he was under the influence of liquor.
Under these conditions, his chances of effectively dealing with changing conditions on the road were
significantly lessened.
THEREFORE, PREMISES CONSIDERED, the decision of the court of Appeals is modified with the
effect of REINSTATING the judgment of the Regional Trial Court.