Case Digest (G.R. No. L-25142)
Facts:
Philippine Rabbit Bus Lines, Inc. and Felix Pangalangan v. Phil‑American Forwarders, Inc., Archimedes J. Balingit and Fernando Pineda, G.R. No. L-25142. March 25, 1975, the Supreme Court Second Division, Aquino, J., writing for the Court.The plaintiffs-appellants were Philippine Rabbit Bus Lines, Inc. (the bus company) and its driver, Felix Pangalangan; the defendants-appellees were Phil‑American Forwarders, Inc., its manager Archimedes J. Balingit, and driver Fernando Pineda. The complaint alleged that on November 24, 1962, Pineda, driving a freight truck owned by Phil‑American Forwarders, Inc., recklessly bumped the bus driven by Pangalangan, causing the driver’s injuries and rendering the bus unusable for seventy‑nine days with loss of earnings of P8,665.51.
The bus company and its driver sued for damages on the theory of quasi‑delict, invoking Art. 2176 and Art. 2180 of the Civil Code (formerly art. 1903). Among the defendants’ pleadings was the contention that Balingit was not Pineda’s employer. Balingit moved to dismiss the complaint against him for lack of cause of action; the Court of First Instance of Tarlac granted the motion and dismissed the action as to Balingit, reasoning that a manager of a corporation is not the “manager of an establishment” contemplated in Art. 2180, and thus cannot be held liable under that provision.
The plaintiffs appealed on pure questions of law to the Supreme Court. On appeal they also urged for the first time that Phil‑American Forwarders, Inc. was essentially a conduit for Balingit and his wife (pointing to their predomin...(Pro-only)
Issues:
- Does the term “employers” and the phrase “owners and managers of an establishment or enterprise” in Article 2180 of the Civil Code include the manager of a corporation so as to render him liable for damages caused by an employee?
- May appellants raise for the first time on appeal an allegation that the corporate veil should be pierced (i.e., that the corporation is merely a conduit of its manager) when that theory was not ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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