Facts:

• On February 7, 1976, at around 6:30 AM, Emerita C. Jumanan was riding a passenger jeepney owned by Virgilio Profeta.
• The jeepney was traveling from Binakayan, Kawit, Cavite to Intramuros, Manila.
• As the jeepney was about to make a left turn below a bridge in Barrio Mabolo, Bacoor, Cavite, a delivery panel from Luau restaurant driven by Domingo Medina and a Saint Raphael Transit bus driven by Leonardo Esguerra were approaching from the opposite direction.
• The Saint Raphael Transit bus, running at high speed, overtook a vehicle and collided with the delivery panel, causing it to swerve into the path of the jeepney.
• The collision resulted in multiple injuries to the jeepney passengers, including Emerita C. Jumanan, who sustained various injuries and fractures.
• Emerita C. Jumanan, assisted by her husband Ricardo Jumanan, filed a complaint for damages against the jeepney owners and operators, Felisa and Tomas Garcia, Emetiquio M. Jarin, and Juanito Madlangbayan, and the driver, Virgilio Profeta.
• The defendants denied liability, attributing the accident to the negligence of the Saint Raphael Transit bus.
• A third-party complaint was filed against Purificacion Samala and Leonardo Esguerra, who then filed a fourth-party complaint against their insurer, Imperial Insurance, Inc.
• The Court of First Instance (CFI) absolved the primary defendants from liability but held the third-party defendants and the insurer jointly and severally liable for damages to the plaintiffs.
• The decision was appealed by the third-party defendants, leading to this case.

Issue:

• (Unlock)

Ruling:

1. Yes, the third-party defendants can be held jointly and severally liable to the plaintiffs even if the principal defendants were absolved from liability.
2. Yes, the plaintiffs can recover damages from the third-party defendants based...(Unlock)

Ratio:

• The Supreme Court explained that under Section 16, Rule 6 of the Revised Rules of Court, a third-party complaint allows a defending party to file a claim against a person not originally a party to the action for contribution, indemnification, subrogation, or any other relief concerning the opponent's claim.
• In this case, the third-party defendants were brought into the action based on their direct liability to the plaintiffs.
• The Court emphasized that it is not necessary for the principal defendants to be adjudged liable before the third-party defendants can be held liable.
• T...continue reading