QUICKY DIGEST: Sps. Parena vs. CA

SPOUSES TEODORO and NANETTE PEREÑA, petitioners, vs. SPOUSES NICOLAS and TERESITA L. ZARATE, PHILIPPINE NATIONAL RAILWAYS, and the COURT OF APPEALS, respondents. G.R. No. 157917. August 29, 2012.

  • Transporting Students
  • Parena and PNR are jointly and severally liable because both of them are negligent.
  • Despite catering to a limited clientèle, the Pereñas operated as a common carrier because they held themselves out as a ready transportation indiscriminately to the students of a particular school living within or near where they operated the service and for a fee.
  • The Pereñas were liable for the death of Aaron despite the fact that their driver might have acted beyond the scope of his authority or even in violation of the orders of the common carrier. 
  • PNR did not ensure the safety of others through the placing of crossbars, signal lights, warning signs, and other permanent safety barriers to prevent vehicles or pedestrians from crossing there.

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