G.R. No. 185757 - Spouses De Guzman, Jr. vs. Court of Appeals

Pedro Ty Belizar, the plaintiff and appellant, filed a complaint on April 21, 1959.
The complaint was against Florencio Brazas, Felix Hilario, Lucio Baldonido, and others.
The subject matter involved the operation of the Samar Express Transit ferry boat.

The plaintiff alleged that the defendants, in their capacity as employees of the Bureau of Public Highways, were grossly negligent.
Due to their negligence in not equipping the ferry boat with necessary safety devices, one of the plaintiff’s auto-trucks fell into the Taft River at Taft, Samar.
The truck remained submerged for over 30 hours, causing both actual and moral damages to the plaintiff.
As a consequence, the plaintiff incurred additional expense by hiring counsel to file the suit.

On May 14, 1959, defendant Felix Hilario filed an answer denying the material allegations and contended he acted under his superiors’ instructions.
On May 19, 1959, defendants Lucio Baldonido, Felix Balato, Teodoro Balato, and Todesco Cebuano filed a motion to dismiss, arguing:

After opposition by the plaintiff, additional motion was filed on May 20, 1959, by defendant Florencio Brazas:

Brazas argued that the complaint improperly sued the defendants in their official capacities.
He maintained that claims for damages should instead be directed against the State.

The lower court, specifically the Court of First Instance of Samar, issued an order on June 6, 1959 dismissing the complaint.
The plaintiff directly appealed the dismissal order to the Supreme Court.

The case is based on a tort action under the doctrine of quasi-delict.
The incident involved negligence related to the absence of safety devices while the government-operated ferry was in service.
Although the Government operated the ferry boat, the plaintiff elected to sue the defendant employees personally for their negligent acts.

Whether the dismissal of the complaint by the lower court was proper under the circumstances.

The court had to determine if the complaint stated a viable cause of action against the defendant employees.
The issue also involved whether suing the defendants in their personal capacities, rather than as representatives of the Government, was procedurally and substantively proper.

Whether the defendants were sued in their official capacities or as private individuals for acts of negligence.
Whether the application of Article 2180 of the Civil Code, regarding the liability for tortious acts of employees, supports personal liability even in the absence of direct supervision.

Whether the provisions of Article 1733 of the Civil Code and the case precedents related to transportation contracts were relevant in a case based on tort rather than contractual obligations.
Determining the correct legal basis for holding employees accountable under quasi-delict principles.