Guillang vs. Bedania| 167 SCRA 363 / G.R. No.

73998 | November 14, 1988

FACTS: Guillang, with three companions was driving his brand new car to Manila. On the other
hand, Bedania was driving a ten-wheeler cargo truck towards Tagaytay. Along the highway and
the road leading to the Orchard Golf Course, Bedania negotiated a U-turn. When the truck
entered the opposite lane of the highway, Guillang's car hit the gas tank at the trucks right
middle portion. The truck dragged Genaros car some five meters to the right of the road.
As a consequence, all the passengers of the car were rushed to the hospital for treatment.
Because of severe injuries, one of the passengers was later transferred to another hospital.
Consequently, he died due to the injuries he sustained from the collision. The car was a total
wreck while the truck sustained minor damage.

ISSUE: Whether Bedania was grossly negligent for recklessly maneuvering the truck by making
a sudden U-turn in the highway without due regard to traffic rules and the safety of other
motorists.
RULING: Yes. Under Article 2185 of the Civil Code, unless there is proof to the contrary, a
person driving a vehicle is presumed negligent if at the time of the mishap, he was violating any
traffic regulation. In this case, the report showed that the truck, while making the U-turn, failed
to signal, a violation of traffic rules. The police records also stated that, after the collision,
Bedania escaped and abandoned the petitioners and his truck. This is another violation of a
traffic regulation. Therefore, the presumption arises that Bedania was negligent at the time of the
mishap. The point of impact was on the lane where the car was cruising. Therefore, the car had
every right to be on that road and the car had the right of way over the truck that was making a
U-turn. Clearly, the truck encroached upon the cars lane when it suddenly made the U-turn.
It is not normal for a truck to make a U-turn on a highway. If Bedania wanted to change
direction, he should seek an intersection where it is safer to maneuver the truck. Bedania should
have also turned on his signal lights and made sure that the highway was clear of vehicles from
the opposite direction before executing the U-turn.