Title
Cadiente vs. Macas
Case
G.R. No. 161946
Decision Date
Nov 14, 2008
A 15-year-old was severely injured by a Ford Fiera; the registered owner and subsequent seller were held jointly liable despite claims of sale, as the vehicle remained registered under the original owner.

Case Digest (G.R. No. L-29881)
Expanded Legal Reasoning Model

Facts:

– On July 19, 1994, at approximately 4:00 p.m. in Davao City, 15-year‑old high school student Bithuel Macas was standing on the shoulder of the road at the intersection of Buhangin and San Vicente Streets when she was involved in an accident. – Eyewitness Rosalinda Palero testified that the victim, who was about two and a half meters away from her, was bumped and run over by a Ford Fiera driven by Chona C. Cimafranca. – Cimafranca promptly took the victim to Davao Medical Center where Dr. Hilario Diaz performed urgent medical treatment. Due to severe injuries—including major vessel and muscular injuries, open bone fractures in both thighs, and other traumatic lesions—a bilateral leg amputation up to the groins was necessary. – The Ford Fiera was registered in the name of petitioner Atty. Medardo Ag. Cadiente. Cadiente, however, claimed that he had sold the vehicle to Engr. Rogelio Jalipa on March 28, 1994, having turned over necessary documents (Certificate of Registration and Official Receipt) with the understanding that Jalipa would secure the transfer. – The victim’s father filed a complaint for torts and damages against Cimafranca and Cadiente. Subsequently, Cadiente filed a third‑party complaint against Jalipa, who in his defense alleged that he, too, had sold the vehicle—purporting a sale to Abraham Abubakar on June 20, 1994. – After trial, the Regional Trial Court ruled in favor of the victim, ordering Cadiente and Jalipa to pay compensatory, moral, and other types of damages. The Court of Appeals affirmed the RTC’s decision, which Cadiente subsequently challenged before the Supreme Court.

Issues:

– Whether there was contributory negligence on the part of the injured party that should reduce or nullify the damages recoverable. – Whether petitioner Cadiente and third‑party defendant Jalipa are jointly and severally liable for the injuries sustained by the victim. – Whether the Court of Appeals erred in holding both defendants jointly and severally liable, despite Cadiente’s contention that his liability should have been limited by shifting reimbursement responsibility to Jalipa under his third‑party complaint.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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