Case Digest (G.R. No. 174156)
Facts:
Filcar Transport Services v. Jose A. Espinas, G.R. No. 174156, June 20, 2012, Supreme Court Second Division, Brion, J., writing for the Court.On November 22, 1998, at about 6:30 p.m., Jose A. Espinas (respondent) was driving along Leon Guinto Street, Manila, when another vehicle struck his car at the intersection of Leon Guinto and President Quirino Streets and fled the scene. Espinas obtained the plate number of the fleeing vehicle and, after verification with the Land Transportation Office, learned that the vehicle was registered in the name of Filcar Transport Services (petitioner). Espinas sent demand letters to Filcar and to its President and General Manager, Carmen Flor, but payment was not made.
On May 31, 2001, Espinas filed a complaint for damages before the Metropolitan Trial Court (MeTC) of Manila, Branch 13, seeking ₱97,910.00 as actual damages. Filcar admitted being the registered owner but claimed the vehicle was assigned to its Corporate Secretary, Atty. Candido Flor, and was at the relevant time driven by Atty. Flor's driver, Timoteo Floresca. Filcar and Carmen Flor denied liability, asserting Floresca was not Filcar’s employee and that due diligence had been exercised in assigning the vehicle.
The MeTC, in a decision dated January 20, 2004, ruled for Espinas and ordered Filcar and Carmen Flor, jointly and severally, to pay actual damages of ₱97,910.00 plus interest, moral damages (₱50,000), exemplary damages (₱20,000), and attorney’s fees (₱20,000). On appeal, the Regional Trial Court (RTC) of Manila, Branch 20, affirmed the MeTC decision, holding that the registered owner is directly and primarily liable for damages caused by operation of a vehicle and that Filcar had failed to prove Floresca was not its employee.
The Court of Appeals (CA), in CA-G.R. SP No. 86603, partly granted relief by modifying the RTC decision: it exonerated Carmen Flor from personal liability (recognizing the corporate separateness of Filcar) but affirmed Filcar’s liability as registered owner under the “registered owner rule,” relying on precedents such as Erezo v. Jepte and Villanueva v. Domingo. The CA denied Filcar’s motion for reconsideration in a resolu...(Pro-only)
Issues:
- May Filcar Transport Services, as the registered owner of the motor vehicle involved in the accident, be held primarily and directly liable for the damages sustained by Jose A. Espinas?
- May Carmen Flor, as President and General Manager of Filcar, be held personally ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
- (Pro-only)