G.R. No. L-69188 - Villaor vs. Trajano

On February 5, 1989, Mayor Fernando Q. Miguel of Koronadal, South Cotabato, was riding in an Isuzu pick-up truck driven by Fidel Lozano, an employee of the Municipality of Koronadal.
The pick-up truck was registered under Rodrigo Apostol's name but was in the possession of Ernesto Simbulan.
Lozano borrowed the vehicle from Simbulan to transport Mayor Miguel to Buayan Airport at General Santos City.
While en route, the pick-up truck struck Marvin C. Jayme, a minor pedestrian crossing the National Highway in Poblacion, Polomolok, South Cotabato.
The collision was severe, propelling Marvin about fifty meters from the impact point, indicating excessive speed.

Marvin suffered severe head injuries including subdural hematoma and diffuse cerebral contusion.
He was initially treated at Howard Hubbard Memorial Hospital and later airlifted to Ricardo Limso Medical Center in Davao City for intensive care.
Despite medical intervention, Marvin died six days after the incident.

Spouses Buenaventura and Rosario Jayme, parents of Marvin, filed a damage suit against respondents before the RTC, seeking actual, moral, exemplary damages, attorney’s fees, and litigation expenses.
They alleged that Lozano's negligent and reckless driving caused Marvin’s death and prayed that all respondents be held solidarily liable.

Apostol and Simbulan averred that Lozano took the vehicle without their consent.
Both Miguel and Lozano denied negligence, arguing that Marvin’s sudden sprint across the highway made the accident unavoidable. Mayor Miguel also denied being aboard at the time of the accident.
The Municipality of Koronadal adopted Lozano and Miguel’s defense.
First Integrated Bonding and Insurance Company, Inc., the insurer, argued that its liability was conditional on the insured filing a claim within the prescribed period, which did not occur, thus extinguishing its liability.

The RTC dismissed the suit against the Municipality of Koronadal, Simbulan, and the insurance company due to lack of liability or cause of action.
The court held defendants Lozano, Apostol, and Mayor Miguel jointly and severally liable, awarding actual damages (PHP 173,101.40 plus legal interest), moral damages (PHP 50,000), exemplary damages (PHP 20,000), attorney’s fees (PHP 20,000), death damages (PHP 50,000), litigation expenses (PHP 3,000), and costs of suit.

Mayor Miguel challenged the RTC ruling and contended that he was not Lozano’s employer, thereby negating his liability for Lozano’s negligence.
He denied negligence and maintained he exercised due diligence and care.
The Municipality of Koronadal was recognized as Lozano’s true and lawful employer.

The CA reversed and set aside the RTC decision insofar as Mayor Miguel was concerned, dismissing the complaint against him.
The CA reasoned that as Mayor Miguel was not Lozano’s employer but merely a passenger, he could not be held liable.
It emphasized the settled rule that liability for damages caused by vehicle operation lies on the registered owner and the negligent driver and their employer.

Whether Mayor Fernando Miguel can be held solidarily liable for the negligent acts of Lozano, the driver assigned to him, resulting in Marvin Jayme’s death.

Whether the Court of Appeals erred in absolving Mayor Miguel of liability despite the facts pointing to his supervisory role over the driver.

Whether the employer-employee relationship exists between Mayor Miguel and Lozano sufficient to impose vicarious liability on the former.