Case Digest (G.R. No. L-50127-28)
Facts:
Victor Juaniza, Heirs of Josefa P. Leus, Etc., et al. v. Eugenio Jose, The Economic Insurance Company, Inc., and Rosalia Arroyo, G.R. No. 50127-28, March 30, 1979, Supreme Court First Division, De Castro, J., writing for the Court.
On November 23, 1969 a passenger jeepney owned and operated in the name of Eugenio Jose collided with a Philippine National Railways freight train, resulting in seven deaths and five persons sustaining physical injuries. At the time, Eugenio Jose was legally married to Socorro Ramos but was cohabiting with Rosalia Arroyo in a long-standing relationship akin to marriage.
Multiple suits for damages arising from the accident were filed in the Court of First Instance of Laguna. That court rendered a decision ordering, among other things, that Eugenio Jose and Rosalia Arroyo be held jointly and severally liable: in Civil Case No. SP-867, P1,500 plus interest to Victor Juaniza; and in Civil Case No. SP-872, P12,000 for the life of each deceased heir, with legal interest and costs. Rosalia Arroyo moved for reconsideration to avoid joint liability, but the trial court denied the motion.
Rosalia Arroyo appealed to the Court of Appeals. The Court of Appeals, treating the question raised as purely one of law, certified the appeal to the Supreme Court. The lone assigned error framed by appellant was that the trial court erred in holding Arroyo liable on the theory that she and Jose, having lived together without marriage, were co-owners of the jeepney under Article 144 of the Civil Code. The legal issues presented were whether Arti...(Subscriber-Only)
Issues:
- Does Article 144 of the Civil Code apply where one party in a common-law relationship is legally incapacitated to marry?
- Can a person who is not the registered owner of a public service vehicle be held jointly and severally liable for damages arising f...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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