Case Digest (G.R. No. 197626)
Facts:
Raul S. Imperial v. Heirs of Neil Bayaban, and Mary Lou Bayaban, G.R. No. 197626, June 24, 2019, Supreme Court Third Division, Leonen, J., writing for the Court.On December 14, 2003 at about 3:00 p.m. on Sumulong Highway, Antipolo City, a Mitsubishi L-300 van (plate USX 931) owned and registered in the name of Raul S. Imperial and driven by his employee, William Laraga, collided with a tricycle (plate DU 8833) driven by Gerardo Mercado carrying spouses Neil and Mary Lou Bayaban. Neil and Mary Lou sustained serious injuries and were treated at Unciano Hospital; their injuries and ensuing therapy were described in medical findings in evidence.
The Bayaban spouses demanded compensation from Imperial, Laraga and Mercado; when their demand went unattended they filed a complaint for damages before the Regional Trial Court (RTC) of Antipolo City (Civil Case No. 04-7131) praying for actual damages, lost earnings, moral and exemplary damages, and attorney’s fees. In his answer Imperial admitted Laraga was his family driver but denied liability, asserting the van had been loaned to one Rosalia Pascua for greenhouse and waterline repairs on Imperial’s Antipolo property, and claiming Laraga was on his rest day (Sunday) and thus acting outside the scope of employment; Imperial also claimed he exercised due diligence in hiring and supervising Laraga and had sponsored Laraga’s formal driving lessons.
Neil died on May 23, 2006 and was substituted by his heirs (Mary Lou and their children). The RTC, in a March 15, 2009 decision, found Laraga negligent (overtaking into oncoming lane) and Imperial liable for failing to prove due diligence in Laraga’s selection and supervision; it awarded actual medical expenses, lost earnings during treatment, moral and exemplary damages, attorney’s fees and costs, ordering Imperial and Laraga to pay jointly and severally. Imperial appealed to the Court of Appeals (CA), which, in a March 18, 2011 decision, affirmed liability but deleted the temperate damages award on grounds the claim was not substantiated and that temperate and actual damages were mutually exclusive; the CA denied reconsideration in a July 11, 2011 resolution.
Imperial filed a Petition for Review on Certiorari before the Supreme Court (Rule 45). The parties filed memoranda per Court directive. Imperial argued that respondents failed to prove Laraga was acting within the scope of his assigned tasks (citing Castilex Industrial Corporation v. Vasquez, Jr.) and...(Pro-only)
Issues:
- Did the Court of Appeals improperly shift the burden to petitioner Raul S. Imperial to prove that his employee William Laraga was not acting within the scope of his assigned tasks?
- Are the original hospital and medical receipts presented by respondents incompetent evidence of actual damages because the...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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