Case Digest (G.R. No. 189122)
Facts:
On March 29, 1967, Malayan Insurance Co., Inc. (petitioner) issued Private Car Comprehensive Policy No. MRO/PV-15753 in favor of Sio Choy, covering a Willys jeep for own damage up to ₱600.00 and third-party liability up to ₱20,000.00 from April 18, 1967 to April 18, 1968. On December 19, 1967 at about 3:30 PM, the insured jeep, driven by Juan P. Compollo (an employee of San Leon Rice Mill, Inc.) collided with a bus of Pangasinan Transportation Co., Inc. (PANTRANCO) in Barrio San Pedro, Rosales, Pangasinan, injuring passenger Martin C. Vallejos and the driver Compollo. Vallejos sued Sio Choy, Malayan Insurance, and PANTRANCO for damages before the Court of First Instance of Pangasinan (Civil Case No. U-2021), seeking actual, moral, and compensatory damages, lost income, medical expenses, and attorney’s fees. PANTRANCO denied liability, attributing fault to excessive speed by the jeep driver. Sio Choy and Malayan Insurance likewise denied fault, claiming PANTRANCO’s negligence. SiCase Digest (G.R. No. 189122)
Facts:
- Insurance Policy
- On March 29, 1967, Malayan Insurance Co., Inc. issued Private Car Comprehensive Policy No. MRO/PV-15753 in favor of Sio Choy, effective April 18, 1967 to April 18, 1968, covering a Willys jeep (Motor No. ET-03023, Serial No. 351672, Plate No. J-21536).
- Coverage included “own damage” up to ₱600.00 and “third-party liability” up to ₱20,000.00.
- Accident and Initial Suit
- On December 19, 1967 at about 3:30 PM, the insured jeep, driven by Juan P. Campollo (employee of San Leon Rice Mill, Inc.), collided with a Pangasinan Transportation Co. bus in Barrio San Pedro, Rosales, Pangasinan.
- Injuries and damage prompted Martin C. Vallejos (passenger) to file Civil Case No. U-2021 for damages against Sio Choy, Malayan Insurance, and PANTRANCO. He claimed: medical/hospital expenses (₱15,000), lost income (₱6,000), actual/moral/compensatory damages (₱51,000), and attorney’s fees (₱5,000).
- Defenses, Cross-claim, Third-Party Complaint
- PANTRANCO denied liability, alleging the jeep’s excessive speed and the bus’s lawful stop; it claimed due diligence.
- Sio Choy and Malayan Insurance denied fault, attributing blame to PANTRANCO. Sio Choy filed a cross-claim against Malayan Insurance for indemnity under the policy.
- Malayan Insurance filed a third-party complaint against San Leon Rice Mill, Inc., invoking employer liability (Art. 2180, Civil Code) for driver Campollo’s negligence, and sought indemnity for any payments made.
- Trial Court Decision
- The Court of First Instance awarded Martin C. Vallejos:
- ₱4,103.00 as actual damages
- ₱18,000.00 for unearned income (3 years)
- ₱5,000.00 as moral damages
- ₱2,000.00 as attorney’s fees
- PANTRANCO’s counterclaim was dismissed for lack of proof.
- Court of Appeals Decision
- Affirmed joint and several liability of Sio Choy, San Leon Rice Mill, Inc., and Malayan Insurance (₱20,000.00 cap).
- Held San Leon Rice Mill, Inc. not liable to indemnify Malayan Insurance due to lack of privity in the insurance contract.
- Supreme Court Proceedings
- Malayan Insurance petitioned for review of the non-indemnity ruling against San Leon Rice Mill, Inc.
- Supreme Court limited review to the insurer’s right of reimbursement; directed execution of the award to Vallejos pending its determination.
Issues:
- Whether Malayan Insurance Co., Inc. can be held solidarily liable with Sio Choy and San Leon Rice Mill, Inc. to Martin C. Vallejos.
- Whether, upon payment to Vallejos, Malayan Insurance is entitled to indemnity or reimbursement from San Leon Rice Mill, Inc.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)