G.R. No. 91378 - 1st Malayan Leasing and Fice Corp. vs. Court of Appeals

The case involves a motor vehicle accident resulting in injuries and fatalities on December 14, 1983.
The accident occurred at the intersection of New York Street and Epifanio delos Santos Avenue (EDSA) in Cubao, Quezon City.
Petitioner's vehicle (First Malayan Leasing and Finance Corporation or FMLFC) was implicated despite its attempted defense regarding ownership.

Crisostomo B. Vitug, the complainant, was driving his car which was at a full stop when the incident unfolded.
An on-coming Isuzu cargo truck, registered in the name of FMLFC and driven by Crispin Sicat, collided with a Ford Granada.
The force of the impact caused the Ford car to hit Vitug's car from behind resulting in severe damage:

The roof of Vitug’s car was crushed, causing significant structural damage.
The rear impact led to the gas tank exploding and eventually setting the car ablaze.

Two passengers of Vitug were fatally injured due to burns.
Vitug sustained injuries causing recurring neck and back pains.
Vitug’s car, valued at P70,000, was declared a total loss.
Personal effects amounting to P48,950 (including a diamond pendant necklace, a GP watch, Christian Dior eyeglasses, a gold Cross pen, and a pair of Bally shoes) were lost.
Medical treatment abroad resulted in substantial expenses (US$2,373.64 on the first trip and US$5,596.64 on the second).

At the time of the accident, the Isuzu cargo truck was still registered in the name of FMLFC.
FMLFC argued that it had sold the truck to Vicente Trinidad on September 24, 1980, under a financing lease agreement and thus was not the owner or employer of the driver.
On the motion of FMLFC, the trial court allowed a third-party complaint against Trinidad, which was later admitted in the proceedings.
The Estate of Vicente Trinidad, while acknowledging that the deceased operated the truck, contended that his estate had been settled and partitioned extrajudicially by his heirs.

The Regional Trial Court of Manila Branch XLIII rendered a decision on August 25, 1986, sentencing FMLFC to pay damages totaling P133,950 plus interest, along with P10,000 for attorneys fees and costs.
The Court of Appeals, on November 27, 1989, modified part of the decision by ordering the Estate of Vicente Trinidad to indemnify FMLFC for amounts paid, except on points where the trial court’s decision was affirmed.
FMLFC then filed a petition for review on certiorari challenging the appellate decision.
The petition was initially dismissed on February 14, 1990, for both procedural deficiencies (lack of proof of service and certified copy of the Court of Appeals’ decision) and late filing.
After a granted motion for reconsideration (April 16, 1990), the petition was reinstated but eventually denied due to lack of merit.

Whether the registered owner, FMLFC, is held liable for damages arising from the accident despite its claim of having sold the truck to Vicente Trinidad.
Whether the registration of the vehicle is conclusive evidence that FMLFC remains the operator for the purposes of public and third-party liability.

Whether a sale or lease, even if valid between private parties, affects third persons if it is not recorded with the Land Transportation Office.
Whether the actual ownership or employment relationship of the driver can override the legal presumption established by the vehicle’s registration.

Whether the petition should be reconsidered considering the initial dismissal on procedural grounds (insufficiency in form and substance, and delayed filing).
Whether the merits of the case justify a reversal of the Court of Appeals’ decision in view of established principles of liability.