G.R. No. L-9605 - Erezo vs. Jepte

The case involves Gaudioso Erezo as plaintiff (or plaintiff-appellee) and Aguedo Jepte as defendant (or defendant-appellant).
The dispute originated from a fatal accident involving a six-by-six truck bearing plate No. TC-1253, registered in the name of the defendant-appellant.
The accident occurred on August 9, 1949, at the intersection of San Andres and Dakota Streets in Manila.

The truck was driven by Rodolfo Espino y Garcia at the time of the incident.
While in motion, the truck collided with a taxicab.
As a consequence of the collision, the truck went off the street and struck two persons, with Ernesto Erezo—son of the plaintiff—suffering fatal injuries.

The driver was prosecuted for homicide through reckless negligence, pleading guilty to the charge.
In criminal proceedings (Case No. 10663, Court of First Instance of Manila), the driver was sentenced to imprisonment and ordered to pay the heirs of Ernesto Erezo the sum of P3,000.
The judgment against the driver could not be enforced against him, prompting the plaintiff to file an action against the registered owner of the truck (defendant-appellant).

The defendant-appellant admitted that, at the time of the accident, the truck was registered in his name.
He asserted that the actual ownership belonged to the Port Brokerage, of which he was merely the broker.
Testimony by Policarpio Franco, the manager of the corporation, corroborated that the vehicles were registered in the defendant’s name as a convenient arrangement to enable the corporation to pay registration fees with his back pay as a pre-war government employee.
It was admitted that this arrangement was not recognized by the Motor Vehicles Office.

The trial court held that the defendant-appellant’s representation to the Motor Vehicles Office, coupled with his registration of the vehicle in his name, created a binding declaration to the government and the public.
Based on this representation, the Court found that the defendant could not later repudiate his declaration to avoid liability.
The court relied on Sec. 68 (a) of Rule 123 and Art. 1431 of the New Civil Code to hold the defendant responsible for the damages.

Whether the defendant-appellant, as the registered owner of the truck, is primarily liable for the damages incurred even though the vehicle’s actual ownership might have been attributed to the Port Brokerage.
Whether the registration of the vehicle creates a presumption that the registered owner is the actual owner, hence binding him to the damages caused by its operation.

Whether the defendant-appellant is entitled to shift liability by proving that he had sold or transferred the vehicle to another party.
Whether the established employer-employee relationship between the driver and the defendant-appellant was properly substantiated at the time of the accident.

Whether allowing the defendant-appellant to prove a transfer of ownership would undermine the public policy aimed at protecting victims of vehicular negligence on public highways.
How the statutory and doctrinal principles under the Revised Motor Vehicles Law affect the determination of liability in such cases.