G.R. No. 197626 - Imperial vs. Heirs of Spouses Bayaban

On December 14, 2003 at about 3:00 p.m., a Mitsubishi L-300 van (plate USX 931) owned by petitioner Raul S. Imperial and driven by his employee William Laraga collided head-on with a tricycle (plate DU 8833) driven by Gerardo Mercado along Sumulong Highway, Antipolo City.
On board the tricycle were spouses Neil and Mary Lou Bayaban, who sustained multiple fractures and were hospitalized at Unciano Hospital, incurring substantial medical and therapy expenses.

The Bayaban spouses demanded compensation from Imperial, Laraga, and Mercado; upon refusal they filed a complaint for damages before the RTC of Antipolo City, praying for actual, moral, temperate, exemplary damages, and attorney’s fees.
Imperial denied liability, asserting the van was lent to Rosalia Pascua for greenhouse maintenance, that Laraga was off duty, and that he had exercised due diligence in selecting and supervising Laraga.
The RTC (2009) found Laraga negligent and Imperial vicariously liable for failing to prove due diligence; awarded actual, moral, temperate, exemplary damages, and attorney’s fees.
On appeal, the CA (2011) affirmed liability, deleted temperate damages for lost earnings but maintained the rest. Imperial’s motion for reconsideration was denied.
Imperial filed a petition for review on certiorari before the Supreme Court.

Whether the CA improperly shifted to petitioner the burden of proving that his employee Laraga was not acting within the scope of his assigned tasks.
Whether the original medical and hospital receipts, unauthenticated under Rule 132, Sec. 20 of the Rules of Court, were incompetent evidence of actual damages.