Facts:

The case at hand involves BA Finance Corporation (petitioner) and several private individuals including Carlos Ocampo, Inocencio Turla, the spouses Moises Agapito and Socorro M. Agapito, and Nicolas Cruz (respondents). The events leading to this case began on March 6, 1983, when an accident occurred involving an Isuzu ten-wheeler truck owned by BA Finance Corporation and driven by Rogelio Villar y Amare, who was an employee of Lino Castro. Subsequently, a lawsuit was filed by the private respondents against BA Finance Corporation, among others.

On October 13, 1988, the Regional Trial Court of Angeles City, Branch LVI, issued a decision mandating the petitioner and co-defendant Rogelio Villar y Amare to jointly and severally pay the private plaintiffs a total of P622,890.00 for damages linked to the accident, while dismissing the case against Lino Castro and the third-party complaint against Rock Component Philippines, Inc. The trial court determined that Villar y Amare was at f

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Facts:

Background of the Incident

• On March 6, 1983, an accident occurred involving an Isuzu ten-wheeler truck registered in the name of BA Finance Corporation (petitioner).
• The truck was driven at the time of the accident by an employee of Lino Castro, not by a direct employee of the petitioner.
• The vehicle, although operated by a driver who was under the control of Lino Castro, was in the petitioner's name and later leased to Rock Component Philippines, Inc.

Proceedings in the Lower Courts

• On October 13, 1988, the Regional Trial Court at Angeles City, Branch LVI, rendered a decision:
• Ordered several liable parties (Rock, B.A. and Rogelio Villar y Amare) to pay damages to the plaintiffs in specified amounts.
• Dismissed the case against Lino Castro.
• Dismissed the third-party complaint against Stronghold.
• Dismissed all counterclaims of the defendants and third-party defendants.
• Ordered Rock to reimburse BA Finance Corporation for the total amount adjudged payable to the plaintiffs.
• The Court of Appeals, with Justice Rasul writing the opinion and Justices De Pano, Jr. and Imperial concurring, affirmed the decision of the lower court largely on the same grounds.

Determination of Liability

• After due trial, the trial court found that Rogelio Villar y Amare, the driver of the truck, was guilty beyond reasonable doubt of reckless imprudence resulting in triple homicide with multiple physical injuries and property damage.
• Petitioner was held liable for damages on the basis that the truck was registered in its name during the time of the accident.
• The court applied doctrines from Perez vs. Gutierrez (53 SCRA 149 [1973]) and Erezo, et al. vs. Jepte (102 Phil. 103 [1957]) to impose such liability.
• The court also invoked Article 2194 of the new Civil Code regarding solidary accountability of joint tortfeasors, covering the liability of the driver, the petitioner, and Rock Component Philippines.

Petitioner’s Arguments and Contentions

• The petitioner argued that:
• Neither the driver nor Lino Castro was an employee or under its direct supervision.
• The vehicle was leased to Rock Component Philippines, implying that the petitioner should not be held directly liable.
• Paragraph 5 of the complaint indicated that it was not the petitioner’s employee who caused the accident.
• The petitioner further contended that:
• The reliance on the Perez and Erezo doctrines was misplaced due to differences in the generative facts of those cases.
• Jurisprudence in Duavit vs. Court of Appeals and Duquillo vs. Bayot suggested that an owner might not be held responsible when the vehicle is operated without consent or when the vehicle has been transferred.
• Article 2180 of the new Civil Code concerning vicarious liability should exempt the petitioner in the absence of an employer-employee relationship with the driver.

Final Outcome

• The petition for review on certiorari was filed challenging the holding and the application of doctrines regarding vicarious liability and registration responsibility.
• The Supreme Court ultimately dismissed the petition and affirmed the decisions of the lower courts without awarding special costs.

Issue:

The Extent of Petitioner’s Liability

• Can BA Finance Corporation be held liable for damages resulting from the accident even though the driver was not its employee?
• Does the fact that the vehicle was leased to Rock Component Philippines, Inc. relieve the petitioner of its liability as the registered owner?

Applicability and Reliability of Doctrinal Precedents

• Is the application of the Perez vs. Gutierrez and Erezo, et al. vs. Jepte doctrines appropriate in imputing liability to the petitioner?
• Can the petitioner rely on the jurisprudence of Duavit vs. Court of Appeals and Duquillo vs. Bayot to escape liability, given the vehicle’s leased status and absence of direct control over the driver?

Interpretation of Motor Vehicle Registration Laws

• Should the principle that the registered owner is prima facie responsible for damages be strictly applied even when the vehicle is not in the owner's physical possession?
• Does the registration under the Revised Motor Vehicles Law impose an absolute presumption of liability irrespective of any contractual lease agreements?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)