Facts:
On July 14, 1997, at around 1:00 a.m.,
Sonny Soriano was crossing
Commonwealth Avenue near
Luzon Avenue in
Quezon City when he was hit by a speeding
Tamaraw FX driven by
Lomer Macasasa. Soriano was thrown about five meters away from the impact point, while the vehicle only stopped around twenty-five meters from where the collision occurred. Although one of Soriano’s companions,
Gerard Villaspin, asked Macasasa to bring Soriano to the hospital, after checking the incident scene, Macasasa returned to the Tamaraw FX and then fled. Soriano was later brought by a school bus to
East Avenue Medical Center, where he later died. The
Quezon City Prosecutor recommended the filing of a criminal case for
reckless imprudence resulting to homicide against Macasasa. On August 20, 1997,
Mutya Soriano (Soriano’s wife) and
Minor Julie Ann Soriano, duly represented by her natural mother and guardian ad litem Mutya Soriano, filed a complaint for damages against Macasasa and against
petitioner Flordeliza Mendoza, the registered owner of the vehicle, in the
Regional Trial Court of Caloocan City, Branch 121 (Civil Case No. C-18038). Respondents sought, among others, moral damages, damages for lost income, funeral and burial-related expenses, exemplary damages, indemnity for the death, and attorney’s fees. In her answer, Mendoza invoked non-liability and alleged that, as owner, she had observed the diligence of a good father of a family in the selection and supervision of Macasasa. Upon respondents’ motion, the complaint against Macasasa was dismissed. After trial, the RTC dismissed the complaint against Mendoza, finding Soriano negligent for crossing through a small gap in the island’s fencing instead of using the pedestrian overpass, and also finding no evidence to support negligence on Mendoza’s part in selecting and supervising Macasasa. On appeal, the
Court of Appeals reversed. It held that although Soriano was negligent, Macasasa was also negligent for speeding and for being unable to avoid hitting the victim, and that Soriano’s negligence did not bar recovery from Macasasa’s negligence. The appellate court further ruled that Mendoza, as employer, was presumed negligent under
Article 2180 of the Civil Code because she failed to present contrary evidence on her diligence in selection and supervision. It thus ordered Mendoza to pay damages, with the total amounts reduced by twenty percent due to Soriano’s
contributory negligence under
Article 2179. Mendoza’s motion for reconsideration was denied on May 24, 2004, prompting her petition for review under
Rule 45, in which she assailed both the RTC’s jurisdiction and the legal basis of the damages awarded.
Issues:
- Did the Regional Trial Court have jurisdiction to try the respondents’ civil action for damages despite Mendoza’s contention that the claim fell within the jurisdiction of the Metropolitan Trial Court?
- Was there sufficient legal basis to hold Mendoza civilly liable for damages arising from the vehicular accident?
Ruling:
Ratio:
Doctrine: